Objecting to the Settlement

If your financial institution is a Settlement Class Member, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. You can give reasons why you think the Court should not approve it. The Court will consider your views. If you object to the Settlement and seek to exclude your financial institution, your financial institution will be deemed to have excluded itself.

Your objection must be in writing, and must include:

  • The name of this Litigation: Village Bank Caribou Coffee Co., Inc. et al, No. 0:19-cv-01640 (D. Minn.);
  • Your financial institution’s full name and the full name, address, email address, and telephone number of the person acting on its behalf;
  • An explanation of the basis for why your financial institution is a Settlement Class Member;
  • Whether the objection applies only to your financial institution, a specific subset of the Settlement Class, or the entire Settlement Class;
  • All grounds for the objection stated, with specificity, accompanied by any legal support for the objection;
  • A description of all evidence to be presented at the Final Approval Hearing in support of the objection, including a list of any witnesses, a summary of the expected testimony from each witness, and a copy of any documents or other non-oral material to be presented;
  • All other information specified in the Preliminary Approval Order (available here), including, but not limited to, information relating to any objections you or your counsel have filed in other class action litigation; and
  • Your signature on the written objection.

Any objection must be either filed electronically with the Court or mailed to the Clerk of the Court, Class Counsel, and Caribou’s counsel at the addresses set forth below. The objection must be electronically filed or, if mailed, postmarked no later than October 22, 2020.


United States District Court
300 South Fourth Street
Minneapolis, MN 55415

Settlement Class Counsel

Bryan L. Bleichner
Chestnut Cambronne PA
100 Washington Ave. S.
Suite 1700
Minneapolis, MN 55401

Defense Counsel

James Slater
Sam Camardo
Key Tower
127 Public Square
Suite 2000
Cleveland, OH 44114-1214

In addition, any Settlement Class Member that objects to the proposed Settlement must make itself available to be deposed regarding the grounds for its objection and must provide, along with its objection, the dates when the objector will be available to be deposed during the period from when the objection is filed through the date seven days before the Final Approval Hearing.