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, shall not exceed twelve (12) pages, and must include:

  • The name of this Litigation: Veridian Credit Union v. Eddie Bauer LLC, No. 2:17-cv-00356 (W.D. Wash.);
  • 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 Eddie Bauer’s counsel at the addresses set forth below. The objection must be electronically filed or, if mailed, postmarked no later than October 4, 2019.


Clerk of the Court
U.S.D.C, Western District of Washington
United States Courthouse
700 Stewart Street
Seattle, WA 98101

Settlement Class Counsel

Gary F. Lynch
1133 Penn Avenue, 5th Floor
Pittsburgh, PA 15222

Joseph P. Guglielmo
230 Park Avenue, 17th Floor
New York, NY 10169

Defense Counsel

Sean B. Hoar
888 SW Fifth Avenue, Suite 900
Portland, OR 97204-2025

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.