A. Remain in the Wisconsin Settlement Class: If you wish to remain a member of the Wisconsin Settlement Class, you do not need to take
any action at this time.
B. Get out of the Wisconsin Settlement Class: If you wish to keep any of your rights to sue Williams about claims concerning the sale of
natural gas during the Class Period, other than claims for product liability, personal injury, or breach of contract claims not related to
the allegations in this litigation, you must exclude yourself from the Wisconsin Settlement Class. If you exclude yourself from the Wisconsin
Settlement Class, you will not get any money from the settlement, and you may not intervene as a party plaintiff in any of the Wisconsin Actions.
To exclude yourself from the Wisconsin Settlement Class, you must send a letter that includes the following:
1) The name, address, and telephone number of the person or entity seeking exclusion;
2) All trade names or business names and addresses that the person or entity seeking exclusion (and any of his, her, or its parents,
subsidiaries, affiliates, predecessors, or assignors who purchased, used, or consumed natural gas during the Class Period) has used during or
since the Class Period;
3) With respect to natural gas purchased, used, or consumed in Wisconsin during the Class Period by any of the entity(ies) listed in
sub-parts 1) or 2) above, the names of all entities from or through whom such natural gas was purchased, an estimate of the total dollar
amount paid for such natural gas in Wisconsin, and an estimate of the total volume of such natural gas purchased in Wisconsin;
4) The case names of the Wisconsin Actions
(Arandell Corporation, et al. v. Xcel Energy, Inc., et al., Case No: 3:07-cv-00076-wmc (W.D. Wis.)
and NewPage Wisconsin System Inc. v. CMS Energy Resource Management Company, et al., Case No: 3:09-cv-00240-wmc (W.D. Wis.
5) The statement that “[name of person or entity] and all of its parents, subsidiaries, and affiliates hereby request to be excluded from the
proposed class settlement described in the notice of settlement pertaining to the Actions;”
6) The title or position of the person signing on your behalf, and a statement that the person is duly authorized to sign on your behalf; and
7) The signature of the duly authorized person identified in subpart 6).
You must mail your exclusion request, postmarked no later than June 5, 2023, to:
C. Remain in the Wisconsin Settlement Class and Object
Natural Gas Claims Administrator
c/o A.B. Data, LTD.
PO Box 173001
Milwaukee, WI 53217-8091
: You can ask the Court to deny approval of the settlement or otherwise object to
the terms of the settlement by filing an objection. You can’t ask the Court to order a larger settlement; the Court can only approve or
disapprove the settlement. If the Court denies approval, no settlement payments will be sent out, and the lawsuits against Williams will
continue. If that is what you want to happen, you must object. If you object, Settlement Class Counsel will not be able to represent you
concerning your objection. It will be your responsibility to assert your objection individually or through counsel that you hire at your own
You may object to the proposed settlement in writing. You may also appear at the Fairness Hearing, either in person or through your own
attorney. In order to appear at the Fairness Hearing, you must first provide written notice of your intention to appear. If you appear through
your own attorney, you are responsible for paying that attorney. All written objections and supporting papers must include (a) a
notice of intention to appear; (b) proof of membership in the Wisconsin Settlement Class; (c) the specific grounds for the objection and any
reasons why you desire to appear and be heard, and (d) all documents or writings that you want the Court to consider.
Any such objection must be mailed to United States District Court for the Western District of Wisconsin on or before May 30, 2023.
The Court’s address is:
D. You cannot both Object to and Exclude yourself from the Settlement
United States District Court
120 N. Henry Street, Room 320
Madison, WI 53703.
: Objecting means you are telling the Court that you want to
be part of the Wisconsin Settlement Class but disagree with something about the settlement terms. You can only object if you intend to stay
in the Wisconsin Settlement Class and be bound by the settlement with Williams if approved by the Court. Excluding yourself, is telling the
Court you do not want to be part of the Wisconsin Settlement Class or the settlement. If you exclude yourself, you have no basis to object
because the settlement no longer affects you. Thus, you cannot both exclude yourself from the Wisconsin Settlement Class and object to the settlement.