What’s The Case About? Where to go: Buyback claims . To learn more about having an attorney from Capstone Law APC represent you in an arbitration for a buyback under the settlement, please go here.

. To learn more about having an attorney from Capstone Law APC represent you in an arbitration for a buyback under the settlement, please go here. Status of your claim . If you already filed a claim, please email the Court-approved claims administrator at: ClaimUpdate@FordTransmissionSettlement.com.

. If you already filed a claim, please email the Court-approved claims administrator at: ClaimUpdate@FordTransmissionSettlement.com. Submit a claim . If you have your documents and are ready to submit your claim, please visit the claims portal on the settlement website.

. If you have your documents and are ready to submit your claim, please visit the claims portal on the settlement website. Learn more about the settlement benefits. Click on the tabs on the left to learn more, or visit the FAQ section on the settlement website. What is this lawsuit about? Our firm, Capstone Law APC, is litigating a lawsuit on behalf of a class of consumers nationwide who purchased or leased a 2011 through 2016 Ford Fiesta and 2012 through 2016 Ford Focus equipped with Ford's Dual Clutch or "PowerShift" Transmission. The lawsuit, entitled Vargas, et al. v. Ford Motor Company (Case No. CV12-08388 AB (FFMx)), has been resolved by a proposed settlement that was preliminarily approved by the United States District Court for the Central District of California, on April 25, 2017 ("the Settlement"). If you purchased or leased a 2011-2016 Ford Fiesta or a 2012-2016 Ford Focus with a PowerShift Transmission (the "Class Vehicles"), you may be entitled to obtain benefits provided by the Settlement and the Orders of the Court.

What is the current status of the Settlement? On March 5, 2020, the Court finally approved the amended settlement and entered judgment. Claims will be processed and payments distributed after the Effective Date of April 7, 2020.

What are the cash payments provided under the Settlement? The settlement offers three types of cash payments. If you have had three or more Service Visits (to Ford dealers) and received a qualifying transmission hardware repair, you are eligible to receive $200 starting with the third visit, another $275 for your fourth visit ($475 in total cash received), up to a cumulative $2,325 for eight visits. If you have had three or more Service Visits where you received a Software Flash (including updates to your transmission control module), you may receive $50 starting with the third visit, and another $50 for each additional visit until you have received $600. If you had a transmission repair refused by a Ford dealer, you may receive a one-time payment of $20 if you attest to those facts.

What are the deadlines for filing a claim for cash payments? There are two deadlines depending on when you made your Service Visits or had a repair request refused. For Service Visits/refused repairs that occurred before the Effective Date of April 7, 2020, the postmark deadline for filing your claim is October 5, 2020. The postmark deadline for Service Visits/refused repairs after April 7, 2020 is 180 days after the date of your Service Visit to the dealer. Claim forms remain available at www.fordtransmissionsettlement.com/submit-a-claim.aspx or by calling the Claims Administrator at (844) 540-6011. We encourage you to seek repairs for your Class Vehicle if you continue to experience transmission malfunctions. Class Members remain eligible for benefits and may submit claims for up to 7 years / 100,000 miles from delivery to the first customer, whichever comes first.

How do I submit a claim for a buyback? The settlement's most valuable relief is a buyback of your vehicle. If you qualify under your state's lemon law (see lemon law resources tab for more), or if you have had 4 Service Visits for transmission hardware repairs within 5 years or 60,000 miles (whichever comes first), you can receive a buyback. Buybacks typically range from $15,000-$22,000. You may be eligible to receive a buyback even if you no longer possess your vehicle . To start the process to receive a buyback, follow the directions provided here: https://consumerarbitrationprogram.com/submitclaim/. Ford will have ten days upon receiving your Notice of Intent to Arbitrate to respond. Ford may offer to provide a buyback directly. (Absent unusual circumstances, you should accept the buyback offer.) After ten days, if you do not receive a buyback offer (or reject the offer), you can proceed to the arbitration program, which is akin to a mini-trial. The program is administered by CAP-Motors, an independent entity vetted by us and Ford, and a neutral arbitrator will review your claims and make a determination as to whether you qualify for a buyback.

What is the deadline for submitting a buyback claim? All Class Members have until at least September 25, 2020 to file a request to arbitrate and until October 5, 2020 to file a request to arbitrate. After that, you have until 6 years of the date of delivery of the vehicle to the first owner to file a request to arbitrate. As a rule of thumb, we suggest that all current and former owner/lessees of a 2011-2014 Ford Focus or Fiesta who qualify for a buyback submit a notice of intent to arbitrate by October 5, 2020 (which requires sending a Notice of Intent to Arbitrate by September 25, 2020). Current or former owners/lessees of 2015-2016 Class Vehicles should submit a Notice of Intent to Arbitrate at least 10 days before your deadline to file your request to arbitrate, which is 6 years of the date of delivery to the first retail owner. Whether to file for the buyback program should be reviewed first with class counsel. Information is also provided on the right-hand corner of this page.

What are my rights as a Class Member? Class Members may be entitled to receive money or other benefits that the Settlement provides. This means that if you did not opt out or otherwise exclude yourself from the Class, you are bound by these results and can no longer sue Ford separately for the same legal claims or claims related to the legal claims alleged in this lawsuit. If you are a Class Member, you may now submit claims for benefits, but please be aware that claims cannot be processed or paid, and no arbitrations can take place, until the Effective Date. Claim forms and other information about the claims process are available at www.FordTransmissionSettlement.com or by calling (844) 540-6011.

What are the other benefits provided by the Settlement? If you paid for a repair to you PowerShift Transmission that you think should have been covered by warranty, you may be entitled to reimbursement or you may compel Ford to make a repair. If your vehicle was manufactured after June 5, 2013, and two or more clutch replacements were performed on your vehicle under warranty and you had to pay for a clutch replacement after warranty, you may be entitled to reimbursement. For more detail, please refer to the FAQ and Summary of Benefits tabs on the left.

What is the advantage of seeking a buyback through the settlement rather than through court? The settlement has created a faster process for getting a buyback. It typically takes 2 to 3 months from the time you file your claim to get an arbitration award for a buyback. Your buyback claim will be decided by an independent arbitrator affiliated with CapMotors (a service unconnected with Ford or class counsel that the parties selected after careful evaluation). While Ford is obligated to pay for the arbitration services and the arbitrator's fees under the settlement, the arbitrator is independent and follows rules negotiated by class counsel. The plaintiffs seeking a repurchase in court has been waiting for over 2 years for relief. Everyone who qualifies for a buyback in court under state law can also get a buyback under the settlement. While some class members may also seek and obtain other relief besides a buyback, if your only claim is for a buyback, you will likely not see any benefit to being in court. But the settlement's arbitration program has several other advantages over a court action. First, former owners/lessees can get a buyback if their state law allows for it, or even if they can show that they had 4 repairs within 5 years/60,000 miles. Second, class members have up to 6 years of the vehicle’s first purchase or 6 months of the final approval order to get a buyback. If you are not a class member, your claim for a buyback may have already expired because there is a short time to seek a buyback in court. Third, class members may get a buyback even if they do not qualify for one under state law. If a class member meets the settlement-created standard, 4 repairs within 5 years/60,000 miles (and the car continues to malfunction), they get a buyback. A lot of class members would otherwise quality to get a buyback under the settlement. As of December 31, 2019, Ford has already paid over $47.4 million for buyback claims.

What are the new terms as part of the Amended Settlement? An amended class settlement was reached between Plaintiffs, Ford, and objecting class members to provide for some additional benefits to the class after a mediation of the parties on December 9, 2019. Most of the current structure and benefits remained in place, but the amended settlement now provides for a $20 one-time payment for class members who were denied repairs, changes so that will make it easier for former owners/lessees to get a buyback in arbitration, and the creation of a $30 million minimum guarantee for the cash payments.

What if a Ford dealer turned me away from getting a Transmission repair? You can receive a one-time payment of $20 if you submit a claim documenting that you were turned away from getting a repair.

SUMMARY OF BENEFITS BASIC INFORMATION REGARDING THE CLASS SETTLEMENT You are a Class Member if: You are a current or former owner or lessee of a 2012-2016 Ford Focus or a 2011-2016 Ford Fiesta equipped with a dual-clutch DPS6 or "PowerShift" automatic transmission ("PowerShift Transmission"); and You do not have a currently pending lawsuit against Ford alleging problems with the PowerShift Transmission. There are several types of compensation available to qualifying Class Members, including (1) Vehicle Repurchase; (2) Cash Payments for Transmission Hardware Replacements; (3) Cash Payments for Software Flashes; and (4) Compensation for Warranty Repairs. Cash payments will be made by pre-paid card. Claims for the qualifying repairs or repair attempts described below, performed by an authorized Ford dealer or repair facility while you owned or leased the vehicle, will be accepted for up to seven years or 100,000 miles from your vehicle's original sale or lease, whichever is earlier. If your repair was made before the Effective Date (projected to be April or May 2020), you must submit your claim within 180 days of the Effective Date. If your repair was made after the Effective Date, you must submit your claim within 180 days of the repair.

CLASS MEMBER BENEFITS BUYBACK/REPURCHASE As a Class Member, you may be eligible for the repurchase or replacement ("buyback") of your car by Ford. Claims for this benefit may depend on your state's "lemon law." Such claims will processed through an expeditious arbitration process. The arbitration administrator, Cap-Motors, was chosen jointly by class counsel and Ford after a careful vetting and is completely neutral. How to Submit a Claim . Before you can claim this relief, you must provide Ford with written notice of your intention to do so at least ten (10) days before you submit your claim. The process can be started at www.consumerarbitrationprogram.com.

Settlement Buyback Standard . Even if you are not eligible under your state's lemon law, you may be eligible under the Settlement's fallback rule if: At least four Transmission Hardware Replacements were performed during separate Service Visits;

All four Transmission Hardware Replacements were performed within five years or 60,000 miles of original delivery to the first owner or lessee; and

Your car is still malfunctioning. Former owners/lessees can qualify for a buyback under this standard if their state law does not permit it. Extension of the statute of limitations . For Class Members who seek a repurchase, you have until 6 years from first sale, or 180 days from the Effective Date (whichever is later), to submit a claim. As a practical matter, every Class Member who may have a viable buyback claim should do so within 180 days of the Effective Date (or by approximately October or November 2020). Attorneys' fees . For class members who prevail in arbitration, the settlement provides that Ford pay up to $6,000 in reasonable attorneys' fees. Civil Penalties . An arbitrator may award civil penalties if the applicable state law provides for it, and if it can be demonstrated that Ford knows of its obligation to provide a buyback under state lemon law and failed to do so. Appeal . You may appeal an arbitrator's award at your own expense. The appeal will be heard by another arbitrator with another arbitration administrator, JAMS. Except for an award of civil penalties, Ford will not be able to appeal an arbitrator’s decision. Cash payments received for Software Flashes or Transmission Hardware Replacements will be deducted from any award made for a repurchase/replacement.

TRANSMISSION HARDWARE REPLACEMENT As a Class Member, you may be eligible for cash payments or discount certificates (to be used toward the purchase of a new Ford vehicle) of increasing value for each Service Visit for a Transmission Hardware Replacement. To submit a claim, please fill out a claim form and follow the instructions on this page: http://www.fordtransmissionsettlement.com/submit-a-claim.aspx Eligibility begins with the third Transmission Hardware Replacement. Payments at $200 for the third Service Visit, an additional $275 for the fourth visit, an additional $350 for the fifth visit, and so on. So, for example, if you have had five service visits, you are eligible to receive $825 in cash ($200+$275+$350).

You may submit claims for up to eight (8) Transmission Hardware Replacements, or up to $2,325 in cash or $4,650 in discount certificates.

Each Transmission Hardware Replacement must have been performed during a separate Service Visit and cannot have been performed as part of a recall program.

Each Transmission Hardware Replacement must have been one of ten (10) enumerated parts that will be listed on your repair order (there may be a prefix or suffix surrounding the part number):

7B546 Disc Asy-Clutch;



7Z369 Control Mod Trans (TCM);



7052 Oil Seal-Trans Rear;



7000 Transmission Asy-Aut;



7C604 Motor-Frt Clutch;



7A508 Rod-Cl/Slave Cyl Pus;



6K301 Seal/RetC/Shft Oil;



7060 Shaft/Bshg Asy-Out;



7048 Seal-Input Shaft Oil; and



7515 Lever Asy-Clutch Rel.

SOFTWARE FLASHES As a Class Member, you may be eligible for a cash payment of $50 for each transmission Software Flash (e.g., TCM update). Eligibility begins with the third Software Flash. To submit a claim, please fill out a claim form and follow the instructions on this page: http://www.fordtransmissionsettlement.com/submit-a-claim.aspx You may submit claims for up to twelve (12) Software Flashes (up to $600).

Each Software Flash must have been performed during a separate Service Visit6 and cannot have been performed as part of a recall program.

Once you submit a claim for a Transmission Hardware Replacement, as described below, this benefit is no longer available to you.

A ONE-TIME $20 PAYMENT If you are not eligible to receive other benefits under the Settlement, you may still be able to receive a $20 one-time payment if you attest to having taken your car in for a Transmission repair but was denied one by your Ford dealer. After the Final Fairness Hearing, the Claims Administrator will provide a form for submitting a claim for $20 payment on this page: http://www.fordtransmissionsettlement.com/submit-a-claim.aspx

FORCED WARRANTY REPAIRS As a Class Member, you may be eligible for compensation for repairs that should have been covered by warranty (breach of the New Vehicle Limited Warranty or its extensions). Such claims will be subject to Arbitration. You must submit your claim to the Arbitration Administrator. The Arbitrator may order one of three (3) forms of compensation, if you win: The repair of your PowerShift Transmission;

Reimbursement of what you already paid to repair your PowerShift Transmission; or

Issuance by Ford of an extended service plan for your car.

REPLACEMENT CLUTCH FOR CERTAIN VEHICLES Certain Class Members may be eligible for reimbursement of costs they paid related to multiple clutch replacements, in addition to an extended warranty on the last clutch installed, if all the following apply: Your car was manufactured after June 5, 2013;

Two clutch replacements were performed within 5 years/60,000 miles of original delivery (to the first owner or lessee);

Your repair order for a third clutch replacement states the need for a new clutch;

The third clutch was replaced within 7 years/100,000 miles of original delivery; and

You paid out-of-pocket for the third clutch.

CLAIMS PROCESS **The Settlement became effective on April 7, 2020. See the Settlement website for more information. Both this website and the Settlement website will be updated regularly as new information is available. Claims for cash payments (pre-paid card) or Vehicle Discount Certificates will be processed by the Claims Administrator, Kurtzman Carson Consultants (KCC). Step 1

Step 2 Logon to the Online Claims Portal to complete your Claim Form OR complete your paper Claim Form, http://fordtransmissionsettlement.com/submit-a-claim.aspx.

Step 2(a) If you intend to submit a claim for repurchase/replacement or breach of warranty, you must give direct notice to Ford at least ten (10) days before you submit the claim by calling (888) 260-4563 or by submitting the notice form available at https://kccsecure.com/fordtransmissionsettlement/Claimant/ArbitrationNoticeForm. If your claim is based on repair attempts, you must prepare and submit to the Arbitration Administrator a declaration attesting to the qualifying attempts. A sample template is available here, for informational purposes only.

Step 3 Upload your supporting documents on the Settlement website or attach hard copies of your supporting documents to your paper Claim Form and mail to: Ford Transmission Settlement

P.O. Box 404000

Louisville, KY 40233-4000

Step 4 The Claims Administrator will review your submission to determine your eligibility.

Step 5 The Claims Administrator will contact you by mail regarding the status of your claim. If your claim is rejected because you failed to submit all the required documents, the Claims Administrator will give you one (1) opportunity to resubmit the claim within thirty (30) days.

Questions regarding the claims process should be directed to the Claims Administrator at www.FordTransmissionSettlement.com or by calling (844) 540-6011. Questions regarding the eligibility for benefits may be directed to Class Counsel at (855) 310-9583 or info@fordpowershiftlawsuit.com.

HOW TO FILE A CLAIM FOR A VEHICLE BUYBACK **Claims will begin processing as soon as practicable after April 7, 2020, the date on which the proposed Settlement becomes legally effective. Due to stay-at-home orders made in connection with COVID-19, there may be delays in processing. This page provides a summary of the process by which claims will be processed after the Approval Date and will be revised as needed. See the Settlement website for more information. Both this website and the Settlement website will be updated regularly as new information is available. Claims for a vehicle buyback/repurchase by Ford or for any breach of Ford’s New Vehicle Limited Warranty will be processed through Arbitration Program. The Arbitration Administrator is CAP-Motors (the Consumer Arbitration Program for Motor Vehicles), administered by DeMars Associates, Ltd. This summary is divided into two sections. First is how to submit claims. Second is what to expect once your claim has been submitted. Deadline: Please be aware that you must submit a request for arbitration by either 6 years of delivery of your vehicle to the first retail customer, or October 5, 2020, whichever is earlier. That means that you have a vehicle with the model year from 2011-2014, you should file a request for arbitration by October 5, 2020. For those with later year models, please check and see when the vehicle was delivered to the first retail customer. You have six years from that date to file a request for arbitration. If you do not know, you should aim for the October 5, 2020 deadline to ensure that you are not time-barred.

How to Submit Claims for a Vehicle Repurchase or Express Warranty Step 1 Gather the documents you need to support your claim (e.g. proof of ownership, repair orders). See FAQ #11.

Step 2 At least ten (10) days before you submit the claim, give direct notice to Ford of your intent to proceed to arbitration by calling (888) 260-4563 or submitting the notice form online. A downloadable version is also available here.1 You will be asked if you are represented by an attorney and, if you are, whether you want Ford to contact you or your attorney. Ford may contact you during the 10-day notice period to offer to informally resolve your claim. If you accept Ford's offer, you will no longer be able to pursue your repurchase claim.

Step 3 After the 10-day notice period has passed, logon to the Arbitration Administrator's Online Claims Portal or complete your paper Claim Form, which will be available at www.FordTransmissionSettlement.com or ConsumerArbitrationProgram.com. Upload your supporting documents on the Arbitration Administrator’s website or attach hard copies of your supporting documents to your paper Claim Form and mail to:

CAP-Motors

c/o DeMars & Associates, Ltd.

Attn: Kyle Morris / Staci Fordinal

P.O. Box 925

Haslet, TX 76052-0925

What to Expect after Submitting your Claim: Step 1 When you submit your claim, you will be asked to select how you want the arbitration to proceed. You may select a document-only review of your claim or a hearing via WebEx (online), via telephone, or in-person. If you choose a review by hearing, oral presentations are allowed in addition to the documents submitted.

Step 2 The Arbitration Administrator will review your submission and contact you regarding the eligibility of your claim. If your submission is deemed incomplete or your claim is deemed ineligible because it doesn’t qualify for a repurchase/replacement, the Arbitration Administrator will notify you in writing. You will have thirty (30) days to correct any deficiencies or appeal the decision.

Step 3 If you choose a review by hearing, the Arbitrator will schedule the hearing and notify you of the date, time, and location (at least two weeks’ notice is required for an in-person hearing). The Arbitration Administrator may contact you to extend the time to schedule the hearing. For example, the time may be extended by ten (10) days if you failed to provide direct notice to Ford at least ten (10) days prior to submitting your claim. It may also be extended if you failed to submit all required paperwork in support of your claim. Finally, the time may be extended for up to thirty (30) days if the Arbitrator requests additional information regarding your claim, including a vehicle inspection. The Arbitration Administrator may contact you to schedule an independent vehicle inspection by an Automotive Service Excellence (ASE) certified technician a vehicle inspection, to be performed ten (10) days before the review of your documents or your arbitration hearing. Alternatively, you may request that your vehicle be inspected before the hearing, the neutral inspection to be arranged by CAP-Motors and paid for by Ford.

Step 4 You must complete a Pre-Arbitration Hearing Information Form and submit it to the Arbitration Administrator at least seven (7) days before your hearing. If you will be represented by an attorney, you must provide your attorney’s information on the form.

Step 5 The Arbitrator assigned to your claim will review your documents, if you select a documents-only review, or hold the hearing online, by phone, or in person, which you must attend. If you select a hearing, all documents that you would like the Arbitrator to review must be submitted no later than seven (7) days before your hearing. If you plan to call witnesses, you must submit a written list of their names at least five (5) days before your hearing.

Step 6 If you select an in-person hearing, you must bring your car, if it is still in your possession, and provide proof of insurance. If your car is not safe to drive or is not operational, tell the Arbitration Administrator before your in-person hearing and explain why it’s not available for inspection. You must attend at the time and place noticed. Please bring copies of all documents originally submitted in support of your claim. If you fail to attend, Ford may still be allowed to argue its case against repurchase/replacement. If you select a documents-only review, you may submit photos and videos. The Arbitrator may also request a vehicle inspection prior to reviewing your documents.

Step 7 The Arbitrator may request additional documents after your hearing, which you will be asked to submit to the Arbitration Administrator.

Step 8 When all evidence has been submitted, including for a document-only review, the Arbitrator will declare the arbitration closed.

Step 9 The Arbitrator will inform you in writing by first-class mail of his or her decision (it will take at least ten (10) days after the arbitration is closed). The entire process from submission of your claim for arbitration to decision should take no more than forty (40) days, excluding any extensions for additional information or to cure deficiencies in the original submission.

Step 10 Within thirty (30) days, you must sign the form provided stating that you accept the Arbitrator’s decision and return it to the Arbitration Administrator. Ford will have thirty (30) days from the date the Arbitration Administrator receives your acceptance to comply with the Arbitrator's award. You may appeal the Arbitrator’s decision regarding a claim for repurchase2, but you are responsible for the additional fees incurred. Ford will reimburse you if you win the appeal. Questions regarding claims for repurchase/replacement or breach of Ford's New Vehicle Limited Warranty should be directed to the Arbitration Administrator at ConsumerArbitrationProgram.com or by calling (800) 279-5343. Questions regarding eligibility for benefits may also be directed to Class Counsel at (855) 310-9583 or info@fordpowershiftlawsuit.com.



Who Are The Lawyers? At Capstone Law APC, we believe that employees should be treated fairly, consumers should get what they pay for, and rights should be protected even when someone cannot afford a lawyer. Capstone Law seeks to represent employees, consumers and investors across the country in litigation involving labor and workplace rights, privacy laws, automobile and other product defects, consumer protection, false advertising or other deceptive trade practices, and securities fraud. Capstone’s attorneys understand the tactics that well-financed defendants use to shield themselves from responsibility. In fact, a number of our attorneys previously worked for large national law firms and graduated from top law schools, including Harvard, University of Michigan, UCLA, and USC. Capstone Law has the talent, experience, financial resources and depth of knowledge to successfully litigate the most complex and challenging cases against the country’s largest corporations when they ignore labor laws and workplace protections, make deceptive claims, violate privacy protections, or sell defective products and services. Our law firm is organized into four main practice areas – Labor & Employment, Consumer Rights, Automotive Defects, and Securities Fraud. We also maintain departments for Mass Actions and Appeals & Complex Motions. Our firm pursues cases in California state and federal courts, as well as in courts around the nation. We also pursue our clients’ claims in arbitration and before administrative agencies. Whatever the forum or venue, Capstone Law invests the time and resources necessary to vigorously prosecute its cases. As part of our commitment to social justice, our firm supports public policy, educational campaigns and legislative efforts to secure and expand the rights of consumers and working people. The firm also publishes the Impact Litigation Journal, a running commentary on important legal developments in the area of representative actions and other complex litigation. Please call us at (866) 955-5890.

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