2 4 6 8 9 UNITED STATES DISTRICT COURT

0 SOUTHERN DISTRICT OF CALIFORNIA

11 12 || ALFONSO and ARLENE MORAN, Case No.: 3:17-CV-02594-JO-AHG individually, and on behalf of a class of 13 || similarly situated individuals, CLASS ACT 14 Plaintiffs, es) 15 vV. FINAL 16 || FCA US LLC, a Delaware limited liability ORDER TO AND 17 || Company, JUDGMENT 18 Defendant.

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1 Having considered Plaintiffs’ Motion for Final Approval of Class Action 2 || Settlement (Dkt. 119) and attachments thereto (the “Motion”), which include the 3 ||parties’ Settlement Agreement (“Settlement Agreement”) and _ supporting 4 || Declarations; Class Counsel’s Fee and Expense Application and Plaintiffs’ Service 5 || Award Application (Dkt. 116) and exhibits thereto; the Declaration of Tarek H. 6 || Zohdy and exhibits thereto; and the Court, having previously granted preliminary 7 ||approval of the Class Settlement on July 13, 2022 and, pursuant to the Amended 8 ||}Order Granting Preliminary Approval of Settlement, Preliminarily Certifying 9 ||Settlement Class, and Approving Class Notice (“Preliminary Approval Order’’) 10 ||(Dkt. 115), provisionally certifying, for settkement purposes only, the proposed 11 || Settlement Class pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil 12 ||Procedure, and having directed the dissemination of Class Notice pursuant to the 13 || approved plan for Class Notice, which the Court has determined to be the best notice 14 || practicable under the circumstances and comporting in all respects with Fed. R. Civ. 15 ||P. 23(e) and due process; and the Court, being satisfied that Class Notice has been 16 || disseminated timely and properly; and the Court, having received no objections to 17 ||the proposed Class Settlement, and having held a final fairness hearing on February 18 || 15, 2023; and the Court, having carefully considered all of the submissions and 19 ||arguments of the parties and being fully advised in the premises, hereby finds and 20 || orders as follows: 21 1. Certification of Class. The Court finds that, for purposes of 22 || Settlement, the applicable prerequisites for class action treatment under Fed. R. Civ. 23 ||P 23(a) and 23(b)(3) are satisfied, to wit: The Settlement Class as defined in Section 24 ||I.L. of the Settlement Agreement, as well as below, are so numerous that joinder of 25 |/all members is not practicable; questions of law and fact are common to the 26 || Settlement Class; the Settlement Class Representatives’ claims are typical of the 27 || Settlement Class’s claims; the Settlement Class Representatives and Class Counsel 28 1 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 ||have fairly and adequately represented, and will continue to fairly and adequately 2 ||represent, the interests of the Settlement Class; questions of law and fact common tc 3 ||the Settlement Class predominate over any questions affecting only individual 4 ||members; and a class action is superior to other available methods for fairly anc 5 || efficiently adjudicating this controversy. The Court need not consider manageability 6 ||issues that might be presented by the trial of a nationwide class action involving the 7 |lissues in this case because the action is being settled rather than litigated. See 8 || Amchem Prods., Inc. v. Windsor,

(1997); In re Hyundai & Kic 9 || Fuel Econ. Litig.,

(9th Cir. 2019) (en banc). 10 2. Notice of the Class Action Settlement. The Court finds that, as 11 demonstrated by the Declaration of Jeremy Talavera and counsel’s submissions, Notice 12 |ito the Settlement Class was timely and properly effectuated in accordance with 13 ||Fed. R. Civ. P. 23(e) and the approved Class Notice plan set forth in the Court’s 14 || Preliminary Approval Order. The Court also finds that said Notice constitutes the 15 || best notice practicable under the circumstances and satisfies all Rule 23(e) and due 16 || process requirements. 17 3. CAFA Notice. The Court finds that, in accordance with the Class 18 || Action Fairness Act of 2005,

(“CAFA”), and as set forth by the 19 || Declaration of Jeremy Talavera, FCA US properly and timely caused to be mailed < 20 ||copy of the proposed class action Settlement and all other documents required by 21 ||law to the Attorney General of the United States and the State Attorneys General in 22 ||each jurisdiction where class members reside. No Attorney General has filed 23 || objections to the Settlement. 24 4. Defined Terms of the Settlement Agreement. Unless otherwise 25 || defined herein, the terms used in this Order shall have the same meaning as set forth 26 |/in the Settlement Agreement, if defined therein. 27 28 2 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 5. The Settlement is Fair, Reasonable and Adequate. The Court finds 2 ||the Settlement satisfies Fed. R. Civ. P. 23 in all respects and is fair, reasonable, 3 |fand adequate. The Court finds the Settlement provides substantial benefits to the 4 || Class, including the following: 5 (a) Defendant expanded the Class Vehicles’ 5-year/60,000-mile powertrain 6 || warranty to include the crankshaft position sensor, thereby extending coverage for 7 ||repair or replacement of engine crankshaft synchronization sensors; 8 (b) The Settlement provides for reimbursement to Class Members for their 9 || out-of-pocket costs paid to repair their Class Vehicle’s crankshaft position sensors 10 ||if the Class Members purchased or leased their Class Vehicles more than five (5) 11 || years before the Effective Date of Settlement and before the Class Vehicle reached 12 ||60,000 miles; 13 (c) FCA shall certify that all replacement crankshaft position sensors 14 installed from the date of Final Settlement Approval are Part Number 68079375AD, 15 || or a subsequent iteration; and 16 (d) Class Members are entitled to an expedited, binding Arbitration for claims 17 || seeking a vehicle repurchase or replacement based in whole or in part on alleged defects 18 ||in the Class Vehicles related to stalling. 19 6. The Settlement is particularly beneficial and appropriate when 20 ||considering the facts and circumstances of this case, the claims and defenses 21 asserted, and the risks of non-recovery or reduced recovery, non-class certification, 22 || and potential recovery delays associated with continued litigation of these claims. 23 7. The Settlement is the Result of Extensive Arm’s-Length 24 || Negotiations and is Not the Product of Collusion. The Court further finds that the 25 || Settlement was entered into as a result of extensive arm’s-length negotiations of 26 ||highly disputed claims, among experienced class action counsel on both sides. The 27 ||Settlement was also negotiated with the assistance of an experienced and highly 28 3 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 ||respected Magistrate Judge, Alison H. Goddard. The Settlement was entered into 2 || with a sufficient understanding by counsel of the strengths and weaknesses of their 3 ||respective cases, and of the potential risks versus benefits of continued litigation. 4 ||including but not limited to the ability to establish and burden of establishing 5 || liability, alleged damages, class certification, and maintenance of class certification 6 || through trial and appeal. 7 8. The Court has considered the factors discussed in In re Bluetooth 8 || Headset Prod. Liab. Litig.,

(9th Cir. 2011) and related decisions. 9 ||and finds the Settlement was entered into in good faith and was not the product of 10 || any collusion between the parties or counsel, whether subtle or otherwise. The Court 11 || finds that, despite a “clear-sailing” provision, which is common in class action 12 ||settlements, the Settlement benefits are not dwarfed by the attorneys’ fees and the 13 Settlement funds do not revert, further supporting a finding of non-collusiveness, 14 || and that attorneys’ fees and expenses were not negotiated until after the parties had 15 ||reached an agreement on the material terms of the Settlement. 16 9. As set forth in the Settlement Agreement, the Court finds that the 17 || Settlement does not and shall not constitute any admission, acknowledgement, or 18 ||evidence of any wrongdoing or liability on the part of Defendant or any Released 19 || Party, or of the merit of any claim or allegation that was or could have been asserted 20 |/in this Action. 21 10. Objections and Requests for Exclusion. There are approximately 22 ||725,817 Settlement Class Members. Class Notice was timely and properly 23 ||implemented pursuant to the Preliminary Approval Order. The Court has received 24 |/no objections to the Settlement. In addition, only 194 Settlement Class Members 25 ||submitted timely and valid requests for exclusion from the Settlement. The Court 26 || finds that the lack of objections and small number of exclusion requests demonstrate 27 28 4 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 |/strongly that the Class favors the Settlement, which further supports the finding 2 ||herein that the Settlement is fair, reasonable, and adequate. 3 11. The Court has considered, and hereby determines, that the 88 requests 4 ||for exclusion collectively identified in the Supplemental Declaration of Jeremy 5 || Talavera dated February 20, 2023, are invalid because they are late and/or deficient. 6 || These requests for exclusion are hereby rejected. 7 IT IS THEREFORE ORDERED THAT: 8 The Court certifies, for the purpose of this Settlement, a Settlement 9 || Class consisting of the following: 10 All current residents of the United States (including 11 territories of the United States) who, prior to the D Preliminary Approval Date, purchased or leased new 2017-2021 Chrysler Pacifica vehicles equipped with a 3.6- 13 liter V6 engine and a 9-speed automatic transmission that 14 were originally sold in the United States (including territories of the United States). 15 Excluded from the Settlement Class are (a) all owners or 16 lessees of Class Vehicles who have filed and served 17 litigation against FCA asserting problems with stalling in Class Vehicles that was pending as of the Notice Date and 18 who do not dismiss their actions before final judgment and 19 affirmatively elect to opt-in to the Settlement. However, Owners or lessees of Class Vehicles who dismiss such 20 litigation and affirmatively opt-in to the Settlement shall 21 be members of the Class for all purposes; (b) FCA’s 0 officers, directors, employees, affiliates and affiliates’ officers, directors and employees; their distributors and 23 distributors’ officers, directors, and employees; and FCA Dealers and FCA Dealers’ officers and directors; (c) judicial officers assigned to the Action and _ their 25 immediate family members, and any judicial officers who may hear an appeal on this matter; (d) all entities and natural persons who have previously executed and 27 delivered to FCA releases of their claims based on stalling 28 in the Class Vehicles; (e) all parties to litigation against 5 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 FCA alleging stalling in Class Vehicles in which final judgment has been entered; and (f) all those otherwise in 2 the Class who timely and properly exclude themselves 3 from the Class as provided in the Settlement. 4 12. The Class certified for the purposes of settlement satisfies all of the requirements of Federal Rules of Civil Procedure 23(a) and 23(b)(3). The Court 6 || finds that (a) the Class of 725,817 Class Members is sufficiently numerous so that 7 joinder would be impracticable; (b) that primary issues in this litigation, namely, 8 || whether Class Vehicles suffer from defects related to the stalling defect, whether and ? || when Defendant had knowledge of the alleged defect, whether Defendant had a legal 10 obligation to disclose the defect, and whether Defendant had the legal obligation to u repair the defect under warranty, are common to the Class; (c) Plaintiffs’ claims are 2 || co-extensive with that of Class Members and are thus typical; (d) Plaintiffs and Class '3 |! Counsel have adequately represented the Class, and there is no conflict between '4 |! Plaintiffs and Class Counsel and other Class Members. The Court also finds a '> || common nucleus of facts regarding the alleged omissions and warranty claims 16 predominate over individual issues, and that a class action is superior because the '7 || Settlement obviates the need for further litigation or trial. 18 13. The Settlement Agreement submitted by the Parties is, in all respects, 19 finally approved pursuant to Fed. R. Civ. P. Rule 23(e) as fair, reasonable, adequate, 20 |! and in the best interest of the Settlement Class. 2k 14. The Court excludes from the Settlement and Release, on the basis of 22 |! their timely and valid requests for exclusion, the 194 Settlement Class Members 23 |l identified in the Declaration of J eremy Talavera. All other requests for exclusion are 24 hereby rejected. 25 15. The Parties are directed to perform all obligations under the Settlement 26 Agreement in accordance with its terms. 27 28 [PROPOSED] FINAL APPROVAL ORDER

1 16. The Parties and each person or entity within the Settlement Class are 2 ||hereby bound in all respects by the terms and conditions of the Settlement 3 || Agreement, including but not limited to the Released Claims against all Released 4 ||Parties contained therein, except for those persons or entities who have duly and 5 ||timely excluded themselves from the Settlement. 6 17. The Action is hereby dismissed, with prejudice and without costs. 7 18. This Final Approval Order has been entered without any admission by 8 ||any Party as to the merits of any allegation in this Action and shall not constitute a 9 || finding of either fact or law as to the merits of any claim or defense that was or 10 |}could have been asserted in the Action. Nothing in this Final Approval Order 11 ||and Judgment, the Settlement Agreement, the underlying proceedings, or any 12 |;documents, filings, submissions or statements related thereto, is or shall be 13 ||deemed, construed to be, or argued as, an admission, or evidence, of any liability, 14 || wrongdoing or responsibility on the part of the Defendant or any Released Party, 15 || or of any allegation or claim asserted in this Action, all of which are expressly denied 16 □□ □□ Defendant. 17 19. The Released Claims, as set forth in the Settlement Agreement, are 18 ||hereby fully, finally, and forever deemed released, discharged, acquitted, 19 ||compromised, settled, and dismissed with prejudice against Defendant and all 20 || Released Parties. Thus, upon the Effective Date of the Settlement, and except for the 21 ||rights and entitlements created by the Settlement, including those under Section II 22 || of the Settlement Agreement, the Plaintiffs and each Class Member shall be deemed 23 ||to have, and by operation of the Final Order and Judgment shall have, released, 24 || waived, and discharged the Released Parties from his, her, or its Released Claims as 25 ||defined in the Settlement, except with respect to claims that qualify for the 26 || Arbitration Program. This release, and the rights and entitlements created by this 27 28 7 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 || Settlement, including those under Section I, will run with the vehicle if the Class 2 Member sells the Class Vehicle. 3 20. The Court, having conditionally appointed Plaintiffs Alfonso and 4 ||Arlene Moran as representatives of the Settlement Class (“Settlement Class 5 || Representatives”) in the Preliminary Approval Order, hereby grants final approval 6 ||of, and appoints, Alfonso and Arlene Moran as Settlement Class Representatives. 7 □□ □□□ Court approves and awards $10,000 to each Plaintiff for their services on behalf 8 || of the Class. The Court finds the Class Representatives have diligently represented 9 || the Class’s interests throughout the litigation and do not have an actual conflict with 10 ||the Class Members 11 21. The Court, having conditionally appointed Class Counsel for the 12 || Settlement Class in the Preliminary Approval Order, hereby grants final approval of, 13 ||and appoints, the law firm of Capstone Law APC as Class Counsel for the 14 || Settlement Class (“Class Counsel” or “Settlement Class Counsel”). The Court finds 15 ||Class Counsel does not have an actual conflict with the Class Members and have 16 ||diligently represented the Class’s interests throughout the litigation. The Court 17 ||awards $835,000 in attorneys’ fees and expenses to Class Counsel. 18 22. The Court, having conditionally approved CPT Group as the Settlement 19 || Administrator, hereby grants final approval of, and appoints, CPT Group as the 20 ||Settlement Administrator to effectuate its duties and responsibilities set forth in 21 ||the Settlement Agreement. After the Effective Date, Defendant may retain a 22 || different Claims Administrator with the agreement of Class Counsel, or, absent 23 ||agreement, with approval of the Court on a showing of good cause. 24 23. The Court has carefully reviewed, and hereby approves, the request for 25 ||a service award of ten thousand dollars ($10,000.00) each to Plaintiffs Alfonso and 26 ||Arlene Moran as reasonable payments for their efforts as Settlement Class 27 ||Representatives on behalf of the Settlement Class, said service award to be paid by 28 8 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 || Defendant in the manner provided in the Settlement Agreement. Said payment shall 2 ||duly, completely, and forever satisfy, release, and discharge any and all obligations 3 ||of Defendant, and any Released Party, with respect to the Settlement Class 4 ||Representative service awards. 5 24. In addition, the Court has carefully reviewed, and hereby approves, 6 ||Class Counsel’s request for an award of reasonable attorneys’ fees, costs and 7 |}expenses in the collective combined total amount of eight hundred and thirty-five 8 ||thousand dollars ($835,000.00) (collectively, the “Fee and Expenses Award”), 9 ||which amount shall be paid by Defendant within the time, and in the manner, 10 ||set forth in the Settlement Agreement. The Court finds said Fee and Expense Award 11 ||to be reasonable and consistent with applicable law. The payment by Defendant of 12 |/said Fee and Expense Award shall constitute full and complete satisfaction of, and 13 ||shall duly, completely, and forever release and discharge the Defendant and all 14 || Released Parties from, and with respect to, any and all obligations for the payment 15 ||of any and all attorney fees, costs, and expenses in connection with this Action 16 || and controversy. 17 25. Without further order of the Court, the Parties may agree to reasonably 18 ||necessary extensions of time to carry out any of the provisions of the Settlement 19 |} Agreement, this Order, and any obligations thereunder. 20 26. Plaintiffs and each and every Settlement Class Member (other than the 21 }|194 Settlement Class Members who submitted timely and valid requests for 22 |;exclusion, the), are hereby permanently barred and enjoined from commencing or 23 ||prosecuting any action, suit, proceeding, claim, or cause of action asserting the 24 ||Released Claims in any court or before any tribunal. This permanent bar and 25 ||injunction is necessary to protect and effectuate the Settlement Agreement, this Final 26 || Approval Order and Judgment, and this Court’s authority to enforce and effectuate 27 ||the Settlement Agreement, and is ordered in aid of this Court’s jurisdiction and to 28 9 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER

1 || protect its judgments. However, this provision will not bar any communications 2 || with, or compliance with requests or inquiries from, any governmental authorities. 3 27. All Class Members who have not made their objections to the 4 || Settlement in the manner provided in the Class Notice are deemed to have waived 5 ||any objections by appeal, collateral attack, or otherwise. 6 28. Without affecting the finality of the Final Approval Order and Final 7 ||Judgment thereon in any away, the Court retains continuing and exclusive 8 || jurisdiction over the Parties, including all Class Members, to enforce the terms of 9 ||the Final Approval Order and Final Judgment, and shall have continuing jurisdiction 10 |}over the construction, interpretation, implementation, and enforcement of the 11 || Settlement Agreement. 12 29. The Court finds that no just reason exists for delay in entering the Final 13 || Judgment. Accordingly, the Clerk is hereby directed to enter Final Judgment. 14 15 || IT IS SO ORDERED. 16 Dated:_2 ( en 17 HonMinsook Ohta 18 United States District Judge 19 20 21 22 23 24 25 26 27 28 10 Case No.: 3:17-CV-02594-JO-AHG [PROPOSED] FINAL APPROVAL ORDER