Frequently Asked Questions

You are receiving the Notice because, according to The General’s records, you submitted a claim for UM or UIM benefits to The General which The General denied by reason of waiver of stacked benefits in The General Policy under which a claim was made. UM/UIM benefits are monies that are paid to compensate persons for injuries sustained in a motor vehicle accident caused by an uninsured motorist, i.e., a driver who has no insurance, or an underinsured motorist, i.e., a driver who does not have sufficient insurance to compensate you for your injuries. Based upon those records, you are a member of a settlement class that has been certified by the Court of Common Pleas for Philadelphia County in a lawsuit brought by Plaintiff Nick Conti, unless you opt out. Please read the website carefully.

The Settlement Class consists of:

All persons who: (a) sustained injury in a motor vehicle accident; (b) who were insureds under a policy that originally provided unstacked uninsured and/or underinsured motorist benefits; (c) where a new vehicle was added to the policy by endorsement, i.e., Amended Declarations Pages not by operation of any “Additional Acquired Auto” or “Newly Acquired Vehicle” clause; (d) where that person made a claim under that The General Policy for recovery of uninsured and/or underinsured motorist benefits; (e) where The General did not obtain a new Waiver of Stacked Uninsured and/or Underinsured Motorist Coverage; and (f) where The General refused to provide stacked coverage.

If the Court grants final approval and there is a final non-appealable judgment and dismissal of this action with prejudice, members of the Settlement Class who do not opt out and whose claims are timely submitted may qualify for payment. The payment to any individual Class Member will not exceed the stacked Policy Declaration Value for UM/UIM coverage in The General policy in question. If you do not opt out of the Settlement, you will be considered a member of the Settlement Class and will be eligible to have your claim evaluated for the possible payment of settlement monies. If you opt out, you will not receive any settlement monies and will not be bound by the settlement, including the release of claims against all The General Insurance Companies.

All Settlement Class Members who do not opt out will be eligible to submit specific information regarding the motor vehicle accident and the injuries sustained in it for evaluation by The General and the possible payment of UM or UIM monies. If you do not agree with The General’s evaluation or the amount of money it offers to pay you for your injuries, the claim will be assigned to a Special Master appointed by the Court to render a final and binding determination.

Settlement Class Members who timely opt out of the Settlement will not be bound by the Settlement and will not release any claims against The General Companies. The Settlement Agreement provides that, under certain circumstances, the Settlement may be terminated. The specific details regarding these termination provisions can be reviewed in the Settlement Agreement on file with the Court and posted on the Case Documents tab.

Complete the Claim Form accompanying the Notice and submit it to the Settlement Administrator, at Conti v. General Automobile Insurance Services Settlement Administrator, P.O. Box 301172, Los Angeles, CA 90030-1172, or by completing the process on the website by clicking "File A Claim", for a determination of whether your claim qualifies for payment and, if so, the amount of payment.

If the Court approves the Settlement, counsel for the Settlement Class will apply to the Court for an award of $577,500 in attorneys’ fees, including costs and expenses. Additionally, counsel for the Settlement Class will apply to the Court for a Service Award to the Class Representative in the amount of $7,500. These amounts are in addition to the Settlement Benefits that may be paid by The General under the Settlement Agreement and will not reduce the Settlement Benefits that may be paid to Settlement Class Members.

Notice is hereby given that the Court has set a date for the Fairness Hearing on January 27, 2026 at 10:00 a.m., before the Honorable Paula Patrick through the following zoom link: https://zoom.us/j/2031203072?pwd=Z3VHaDdGREEzY21ST0FWNDh4ZkNSZz09  at the Court of Common Pleas, City Hall Philadelphia, PA 19107, for the purposes of determining the reasonableness, adequacy and fairness of the Settlement of this Action as set forth in the Settlement Agreement. At the Fairness Hearing, the Court will consider: (a) whether the Settlement should be approved as fair, reasonable, and adequate and whether the Released Claims of the Settlement Class against the Released Persons should be dismissed with prejudice; (b) Class Counsel’s motion for an award of attorneys’ fees, costs and expenses; and (c) the Named Plaintiffs’ Service Award.

Anyone who objects to the Settlement, the Settlement Agreement, the application for attorneys’ fees, or other matters to be considered at the Fairness Hearing may appear and present such objections or petition to intervene. In order to be permitted to do so, however, you must, on or before December 5, 2025:

• File with the Court your objection and notice to appear, together with a statement setting forth your petition to intervene or your objections, if any, to the matter to be considered and the basis for these objections, together with any documentation that you intend to rely upon at the Fairness Hearing, and comply with all the prerequisites to an objection set forth in the Settlement Agreement; and
• Serve copies of all such materials either by hand delivery or by first-class mail, postage pre-paid, upon the following counsel:

Jonathan Shub
Shub, John & Holbrook LLP 
Four Tower Bridge
200 Bar Harbor Dr Suite 400
West Conshohocken, PA 19428

Adam Arceneaux
Ice Miller LLP
One American Square Suite 2900
Indianapolis, IN 46282

Any notice of intent to object must: (a) attach documents establishing, or provide information sufficient to allow the Parties to confirm, that the objector is a Class Member; (b) include a statement of such Class Member’s specific Objection; (c) state the grounds for the Objection; (d) identify any documents such objector desires the Court to consider; and (e) provide all information requested on the Claim Form. In addition, any Class Member objecting to the Settlement shall provide a list of all other Objections submitted by the objector, or the objector’s counsel, to any class action settlements submitted in any Court in the United States in the previous five years. If the Settlement Class Member or his/her or its counsel has not objected to any other class action settlement in the United States in the previous five years, he/she or it shall affirmatively so state in the Objection.

Unless otherwise ordered by the Court on or before January 27, 2026, based upon an appropriate motion, the Fairness Hearing shall be conducted solely based upon your written petition to intervene or objections filed with the Court, as provided herein, and the argument of counsel.

If you do not comply with the foregoing procedures and deadlines for submitting written petitions to intervene, objections and/or appearing at the Fairness Hearing, you may lose substantial legal rights, including but not limited to, the right to appear at the Fairness Hearing; the right to contest approval of the Settlement or the application for an award of attorneys’ fees and costs to Class Counsel; the right to contest approval of the application for a Service Award to the Class Representatives; or the right to contest any other orders or judgments of the Court entered in connection with the Settlement. If the Court does not approve the Settlement, the Settlement Agreement will be null and void.

If you do not want to be a member of the Settlement Class and participate in the Settlement, then NO LATER THAN May 12, 2025, you must send  a signed statement to that effect that includes your name, address, and telephone number. The signed statement must be sent to the following:

Conti v. General Automobile Insurance Services Settlement Administrator

P.O. Box 301172
Los Angeles, CA 90030-1175

TO BE CONSIDERED TIMELY AND TO EFFECTIVELY OPT OUT OF THE SETTLEMENT CLASS, YOUR COMPLETED SIGNED STATEMENT ADVISING OF YOUR ELECTION TO OPT OUT MUST BE POST-MARKED NO LATER THAN MAY 12, 2025. IF IT IS NOT POSTMARKED BY THAT DATES, YOUR RIGHT TO OPT OUT WILL BE DEEMED WAIVED AND YOU WILL BE BOUND BY ALL ORDERS AND JUDGEMENTS ENTERED IN CONNECTION WITH THE SETTLEMENT.

If you choose to opt out of the Settlement Class, you will not be entitled to receive the benefits of the Settlement with The General, including any settlement payment. Your claims against The General will not be released and you will be free to separately pursue any claims you believe you have.

The foregoing references to the pleadings, Settlement Agreement and other documents, and their respective contents are only summaries thereof. For further details with respect to the Settlement Agreement, the pleadings, the claims asserted in the Action, and the matters to be heard at the hearing, reference may be made to the complete files of this Action which may be examined at the above-mentioned courthouse at any time during regular office hours. Additionally, important documents, including the Settlement Agreement, which may be accessed here.

As a part of the Settlement, Class Members agree to release The General and not to sue The General for any and all manner of actions, causes of action, suits, accounts, claims, demands, controversies, judgments, obligations, damages and liabilities of any nature whatsoever, whether ex contractu or ex delicto, debts, liens, agreements, interests, costs, expenses, attorneys’ fees, losses or damages (whether actual, consequential or treble) statutory, common law or equitable, including but not limited to breach of contract, bad faith or extra-contractual claims, and claims for punitive or exemplary damages, or pre- or post-judgment interest, whether or not now known, suspected or claimed, from the beginning of time to the date of this Release: (a) that were asserted, or could have been asserted, by or on behalf of Plaintiffs, as Releasing Parties, against The General, or any other Released Person, in connection with, relating to or arising out of the Action; or (b) that were asserted, or could have been asserted, by or on behalf of any Class Member, as Releasing Parties, against any Released Person, in connection with, relating to or arising out of the denial by any of the Released Persons of the Class Members’ uninsured or underinsured motorist claims seeking benefits under Pennsylvania motor vehicle insurance policies by reason of the household or regular use exclusion during the relevant time period, including but not limited to claims in connection with, relating to or arising out of the conduct alleged in the Action.

If you have questions regarding the Notice or the Settlement and the Action generally, you can obtain additional information from the following sources:

Counsel for the Settlement Class:

You may also contact the Settlement Administrator by phone at 1-833-769-6848, or email at [email protected].

DO NOT CALL THE COURT OR THE GENERAL WITH QUESTIONS.