NOTICE OF CLASS ACTION SETTLEMENT
in
Aluminum Precision Products, Inc. ESOP Litigation
Moran v. ESOP Committee of the Aluminum Precision Products, Inc. Employee Stock Ownership Plan, Case No. 8:24-cv-00642-MWF-ADS (C.D. Cal.)

PLEASE READ THE SETTLEMENT NOTICE CAREFULLY.
The Notice is in regards to a proposed class action Settlement in the above-referenced Lawsuit.
If you are a member of the Class, the Settlement will affect your legal rights.
This is not a solicitation from a lawyer.
You have not been sued.

  • A Settlement has been reached in a class action lawsuit concerning the Aluminum Precision Products, Inc. Employee Stock Ownership Plan (the “Plan”). The class action lawsuit involves whether the Plan was managed by Defendant ESOP Committee of the Aluminum Precision Products, Inc. Employee Stock Ownership Plan in accordance with certain provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”). Defendant denies all claims, and nothing in the Settlement is an admission or concession on Defendant’s part of any fault or liability whatsoever.
  • The Settlement will provide, among other things, for a $2 million Qualified Settlement Fund that will be allocated to eligible Settlement Class Members after any Court-approved deductions for Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation.
  • Settlement Class Members who have an account in the Plan at the time that settlement distributions are made such that their distribution can be deposited into their individualized account in the Plan (referred to herein as “Current Participants”) will automatically receive allocations directly to their individualized accounts. Class Members who are not Current Participants have the option to receive their settlement distribution in the form of a check, or in the form of a tax-qualified rollover to an individual retirement account or other eligible employer plan if they elect a rollover. A Rollover Form allowing you to elect to receive your distribution in the form of a rollover is attached to the Notice that was sent to you in the mail.
  • The terms and conditions of the Settlement are set forth in the Settlement Agreement dated April 13, 2026. Capitalized terms used in the Notice but not defined in the Notice have the meanings assigned to them in the Settlement Agreement. The Settlement Agreement is available at www.appesopsettlement.com. Certain other documents also will be posted on this website. You should visit this website if you would like more information about the Settlement or the lawsuit. All papers filed in this lawsuit are also available for review via the Public Access to Court Electronic Records System (PACER), at http://www.pacer.gov.
  • The Settlement Class (whose members are “Settlement Class Members”) includes all participants and beneficiaries of the Plan since the date that is six years prior to the filing of this Action, excluding anyone who served on the ESOP Committee of the Aluminum Precision Products, Inc. Employee Stock Ownership Plan during that period.
  • Your rights and the choices available to you—and the applicable deadlines to act—are explained in the Notice. Please note that neither APP nor any employees, attorneys, or representatives of APP may advise you as to what the best choice is for you or how you should proceed.
  • The Court still has to decide whether to give its final approval to the Settlement. Payments under the Settlement will be made only if the Court finally approves the Settlement, and that final approval is upheld in the event of any appeal.
  • A Final Fairness Hearing will take place on September 16, 2026, at 10:00 a.m., before the Honorable Michael W. Fitzgerald, United States District Court for the Central District of California, 350 W First Street, Los Angeles, CA  90012, in Courtroom 5A (Fifth Floor), to determine whether to grant final approval of the Settlement and approve the requested Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation. If the Final Fairness Hearing is rescheduled, or if it is held by video conference or telephone, a notice will be posted on the Settlement Website at www.appesopsettlement.com.
  • Any objections to the Settlement, or to the requested Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation must be filed with the Clerk of Court and served in writing on Class Counsel and Defense counsel, as identified in Item 11 below.
YOUR LEGAL RIGHTS AND OPTIONS UNDER THE SETTLEMENT:
If you are a Current Participant in the Plan:You do not need to do anything to receive your share of the Net Settlement Amount. If, however, you do not have an account in the Plan at the time that distributions are made, you will receive your settlement distribution in the form of a check or rollover, if elected.
If you are Not a Current Participant in the Plan:You do not need to do anything to receive your share of the Net Settlement Amount by check. However, if you wish to receive your share of the Net Settlement Amount via a rollover to an individual retirement account or other tax-qualified employee benefit plan, then you must submit a Rollover Form postmarked on or before September 2, 2026. A Rollover Form is attached to the mailed Notice and also may be obtained by calling the Settlement Administrator at 1-800-485-9315 or by accessing www.appesopsettlement.com.
You can Object (No later than August 26, 2026)If you wish to object to any part of the Settlement, or to the requested Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation, you must file and postmark your objection and any supporting documents with the Clerk of the Court, and mail copies to Class Counsel and Defendant’s counsel (as identified under question 11 below) at least twenty-one (21) calendar days before the Final Fairness Hearing. Please note that you will not be permitted to make an objection to the Settlement if you do not comply with the requirements for making objections.
You can Attend a Hearing on September 16, 2026You may also attend the Final Fairness Hearing and speak at the Final Fairness Hearing on September 16, 2026. If you wish to speak at the Hearing, you must provide Class Counsel and Defendant’s counsel (as identified under question 11 below) with your notice to appear postmarked at least fourteen (14) calendar days before the Final Fairness Hearing. Please note that you will not be permitted to speak at the Final Fairness Hearing if you do not comply with the requirements for making objections.

The Class Action

The case is called Moran v. ESOP Committee of the Aluminum Precision Products, Inc. Employee Stock Ownership Plan, Case No. 8:24-cv-00642-MWF-ADS (C.D. Cal.) (the “Class Action” or “lawsuit”). It has been pending since March 27, 2024. The Court supervising the case is the United States District Court for the Central District of California. The individual who brought this lawsuit is called the Class Representative, and the party that was sued is called the Defendant. The Class Representative—Gustavo Moran—is a current participant in the Plan. Defendant is the ESOP Committee of the Aluminum Precision Products, Inc. Employee Stock Ownership Plan. The claims in the lawsuit are described in Item 2 in the Frequently Asked Questions page of this website, and additional information about them, including a copy of the operative Complaint, is available at www.appesopsettlement.com.

The Settlement

Following negotiations with the Class Representative, Class Counsel, Defendant, and Defense Counsel, a Settlement has been reached. As part of the Settlement, a Qualified Settlement Fund of $2,000,000.00 will be established to resolve the claims against Defendant in the Action. The “Net Settlement Amount” is $2,000,000.00 minus any Court-Approved Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation. The Net Settlement Amount will be allocated to Settlement Class Members according to a Plan of Allocation to be approved by the Court and further described below in Item 5.

Statement of Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation Sought in the Class Action

Class Counsel has devoted significant time over the last two years to investigating the facts of this case, prosecuting the lawsuit, reviewing documents obtained from Defendant and third parties, and negotiating the Settlement. During that time, they also have advanced all costs, including litigation expenses and travel costs, necessary to pursue and resolve the case. Class Counsel took the risk of litigation and have not been paid for any of their time or for any of these costs throughout the time this case has been pending.

Class Counsel will apply to the Court for payment of Attorneys’ Fees for their work in the case. The amount of fees that Class Counsel will request will not exceed one-third of the Qualified Settlement Fund ($666,666.66). In addition, Class Counsel also will seek to recover their litigation costs advanced and Administrative Expenses associated with the Settlement. Any Attorneys’ Fees, Costs, and Administrative Expenses awarded by the Court will be paid or reimbursed from the Qualified Settlement Fund.

Class Counsel also will ask the Court to approve payments, not to exceed $5,000, for the Class Representative who aided in the investigation, took on the risk of litigation, participated in discovery, prepared for and consulted with his counsel in settlement negotiations, and committed to spend the time necessary to bring the case to conclusion, including testifying at trial. Any Class Representative Compensation awarded by the Court will be paid from the Qualified Settlement Fund.

A full and formal application for Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation will be filed with the Court on or before August 17, 2026, and will explain the bases for awarding Attorneys’ Fees and Costs, Administrative Expenses, and Class Representative Compensation. This application will be made available at www.appesopsettlement.com. You may also obtain a copy of this application through the Public Access to Court Electronic Records System (PACER) at http://www.pacer.gov, or by appearing in person during regular business hours at the Clerk’s Office of the United States District Court for the Central District of California, 350 W First Street, Los Angeles, CA 90012.