• A Settlement has been reached in a class action lawsuit between Defendant Georgetown University (“Defendant” or “Georgetown”) and certain individuals who have alleged that they, and the Settlement Class Members, are entitled to partial refunds of tuition and fees for the Spring 2020 Semester because Georgetown transitioned to remote instruction in March 2020 amid the COVID-19 pandemic in accordance with District of Columbia legal mandates.  The case is Gur-Ravantab, et al. v. Georgetown University, Case No. 1:22-cv-01038, in the United States District Court for the District of Columbia (the “Lawsuit”).  The proposed Settlement is not an admission of wrongdoing by Georgetown, and Georgetown denies all allegations of wrongdoing and disclaims all liability with regard to all claims in the Lawsuit.  The Court has granted Motion for Preliminary Approval of Class Action Settlement and has directed that this notice be sent.
• You are a member of the Settlement Class if you were a Georgetown undergraduate student enrolled during the Spring 2020 Semester for whom any amount of that Semester’s tuition and/or fees was paid from any source other than a scholarship/grant from Georgetown (e.g., your own funds, funding from a parent or other family member, a loan, or a non-Georgetown scholarship/grant), and whose tuition and fees have not been fully refunded.  You are not a Settlement Class Member if you opt out of the Settlement, if your Spring 2020 Semester tuition and fees were fully covered by scholarship and/or grant money from Georgetown, or if you otherwise were not obligated to make contributions, payments, or third-party arrangements towards tuition or fees for the Spring 2020 Semester.
• Under the Settlement Agreement, Georgetown will pay $1.5 million into a Settlement Fund.  Some of that will go to Class Counsel for attorneys’ fees and expenses, some will go to the Lead Plaintiffs as service awards, and some will pay for the costs of administering the settlement.  What remains of the $1.5 million will be divided pro rata among the approximately 6,300 Settlement Class Members.  Settlement Class Members do not need to take any action to receive their shares of the payment.  Settlement Class Members will automatically receive their shares by check mailed to the Settlement Class Member’s last known mailing address.  Alternatively, if they prefer to receive their share by Venmo or PayPal, or update their mailing address for mailing of a check, Settlement Class Members may visit the settlement website to complete an Election Form to provide their Venmo or PayPal information, or to update their mailing address.

The lawsuit alleges that students who were enrolled as undergraduates at Georgetown during the Spring 2020 Semester are entitled to partial refunds of tuition and fees because Georgetown transitioned to remote instruction in March 2020 amid the COVID-19 pandemic in accordance with District of Columbia legal mandates.  Georgetown denies each and every allegation of wrongdoing, liability, and damages asserted, and Georgetown denies that the claims in the Lawsuit would be appropriate for class treatment if the litigation proceeded through trial.

The Plaintiffs’ Complaint, the Settlement Agreement, and other case-related documents are available here.

A class action is a lawsuit in which a person called a “Lead Plaintiff” or “Class Representative” (or several of them) sue(s) on behalf of people with similar legal claims.  These people, all together, are called a “Settlement Class” or “Settlement Class Members.”  The Settlement, if finally approved by the Court, resolves the issues for all Settlement Class Members, except for those who exclude themselves from the Settlement Class. 

The Plaintiffs and Georgetown have determined that it is in their best interests to settle and avoid the expenses and uncertainties associated with continued litigation.  This Settlement resolves all claims asserted in the case against Georgetown and its affiliated persons and entities.  The Plaintiffs and the attorneys for the Settlement Class believe the proposed settlement is in the best interests of the Class.  The Settlement is not an admission of wrongdoing by Georgetown and does not imply that there has been, or would be, any finding that Georgetown violated any law if the case were to move forward.  Georgetown denies each and every allegation of wrongdoing and liability in the Lawsuit.  The Court did not reach a decision on the merits of the Lawsuit.  The Court has granted a Motion for Preliminary Approval of Class Action Settlement and ordered that this notice be provided to explain it.  Nevertheless, because the settlement of a class action determines the rights of all members of the class, the Court must give final approval to the Settlement before it can be effective.  The Court has directed that Settlement Class Members receive this Notice and have the opportunity to exclude themselves from the Settlement Class or to voice their support for or opposition to final approval of the Settlement.  If the Court does not give final approval to the Settlement, or if the Settlement is terminated by the Parties, the Settlement will be void, and the lawsuit will proceed as if there had been no settlement and no certification of the Settlement Class.

You are a member of the Settlement Class if you were a Georgetown undergraduate student enrolled during the Spring 2020 Semester for whom any amount of that Semester’s tuition and/or fees was paid from any source other than a scholarship/grant from Georgetown (e.g., your own funds, funding from a parent or other family member, a loan, or a non-Georgetown scholarship/grant), and whose tuition and fees have not been fully refunded.  You are not a member of the Settlement Class if you are excluded from the Settlement Class.  Excluded from the Settlement Class are:

1. any Judge or Magistrate Judge presiding over this Action and members of their families;
2. Defendant;
3. persons who properly execute and file a timely request for exclusion from the class;
4. the legal representatives, successors or assigns of any such excluded persons; and
5. Georgetown undergraduate students who received a full scholarship from Georgetown or otherwise were not obligated to make contributions, payments, or third-party arrangements towards tuition or fees for the Spring 2020 Semester.

1. Receive Payment By Check or Elect to Have Your Payment Made Electronically.

The $1.5 million Settlement Fund, minus any attorneys’ fees for Class Counsel, service awards for the Lead Plaintiffs (addressed below), and the costs of administering the settlement, will be divided pro rata among all Settlement Class Members.  You will not need to take any action to receive your share of the settlement.  Settlement Class Members will automatically receive their Cash Award by check mailed to the Settlement Class Member’s last known mailing address as reflected in Georgetown’s records.  Alternatively, if they prefer to receive their share by Venmo or PayPal, they may visit the settlement website to provide their Venmo or PayPal information, or may provide that information to the Settlement Administrator by mail at the address below.  If any Settlement Class Members fail to cash their Cash Award checks, those monies from uncashed checks will be deposited in the general scholarship fund for the purpose of providing additional student aid.

2. Exclude Yourself (“Opt out” of the Settlement).

You may exclude yourself from the Settlement.  If you do so, you will not receive a Cash Award from the Settlement Fund.  You will not release any claims you may have against Georgetown and the Released Parties (as that term is defined in the Settlement Agreement, available for review here, and you will be able to pursue whatever legal rights you may have at your own risk and expense.

To exclude yourself from the Settlement, you must mail a timely letter to the Settlement Administrator at: Georgetown University Settlement Administrator, c/o Settlement Services, Inc., PO Box 2715, Portland, OR 97208-2715, postmarked by October 12, 2024.  Your request to be excluded from the Settlement must include your name and address, and a statement that you want to be excluded from the Settlement Class for purposes of this Settlement in Gur-Ravantab, et. al v. Georgetown University, Case No. 1:22-cv-01038, in the United States District Court for the District of Columbia.  You cannot ask to be excluded by phone or on the Settlement Website.  You may opt out of the Settlement Class only for yourself; one may not purport to opt others out of the Settlement Class on a class or representative basis.  “Mass” or “class” opt-outs will not be allowed.

3. Object to the Settlement.

If you are a Settlement Class Member (and do not exclude yourself from the Settlement Class), you can object to any part of the Settlement.  You can ask the Court to deny approval of the proposed settlement by filing an objection.  You cannot ask the Court to order a larger settlement; the Court can only approve or deny the Settlement.  If the Court denies approval, the benefits for Settlement Class Members described herein will not be provided, and the lawsuit will continue.

To object, you must file your objection in writing with the Court by October 12, 2024.  Your objection must include the following:

• Your name and address;
• An explanation of the basis upon which you claim to be a Settlement Class Member;
• All grounds for the objection, including all citations to legal authority and evidence supporting the objection;
• The name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection (the “Objecting Attorneys”);
• A statement indicating whether you intend to appear at the Final Approval Hearing (either personally or through counsel who files an appearance with the Court in accordance with the Local Rules); and
• If you or any of the Objecting Attorneys has objected to any class action settlement where the objector or the Objecting Attorneys asked for or received any payment in exchange for dismissal of the objection, or any related appeal, without any modification to the settlement, a statement identifying each such case by full case caption and amount of payment received.

“Mass” or “class” objections will not be allowed.

If you do not timely and validly make your objection, you will be deemed to have waived all objections and will not be entitled to speak at the Final Approval Hearing.

If you file and serve a written objection and statement of intent to appear, you may appear at the Final Approval Hearing, either in person or through your personal counsel hired at your own expense, to object to the fairness, reasonableness, or adequacy of the Settlement.

If you wish to object, you must file your objection with the Court (using the Court’s electronic filing system or in any manner in which the Court accepts filings) no later than October 12, 2024.  You must also send a copy of your objection by mail, hand, or overnight delivery service (or by operation of the Court’s CM/ECF system) to the attorneys representing the Plaintiffs and the Settlement Class (specifically Michael Tompkins or Anthony Alesandro of Leeds Brown Law, P.C., One Old Country Road, Suite 347, Carle Place, NY 11514) and the attorneys representing Georgetown University (Alan E. Schoenfeld of Wilmer Cutler Pickering Hale and Dorr LLP, 7 World Trade Center, 250 Greenwich Street, New York, NY 10007), postmarked no later than October 12, 2024.

If you hire an attorney in connection with making an objection, that attorney must also file with the Court a notice of appearance by October 12, 2024.  If you do hire your own attorney, you will be solely responsible for payment of any fees and expenses the attorney incurs on your behalf.  If you exclude yourself from the Settlement, you cannot file an objection.  If you object and the Settlement is approved, you will still be entitled to receive benefits under the Settlement, and will be bound by the terms of the Settlement.

Lead Plaintiff Compensation. The Court may award reasonable service compensation to the Lead Plaintiffs for their service in the case, not to exceed seven thousand dollars (7,000.00) total, which shall come from the Settlement Fund.  Any such Court-ordered compensation shall be paid within twenty-one (21) business days after the Effective Date.  This shall be in addition to any Cash Award that the Lead Plaintiffs may receive as Settlement Class Members.

Class Counsel Attorneys’ Fees, Costs, and Expenses. The attorneys who brought the lawsuit (listed below) will ask the Court to award them attorneys’ fees not to exceed one-third (33.33%) of the Settlement Fund ($500,000.00) plus reimbursement of costs and expenses in an amount not to exceed seventy-five thousand dollars ($75,000.00), for the time, expense and effort expended in investigating the facts, conducting the litigation, and negotiating the Settlement.  Class Counsel’s motion for attorneys’ fees, costs and expenses, and Lead Plaintiff service awards will be filed with the Court and made available on the Settlement website no later than November 7, 2024.  The Fee Award shall be payable by the Settlement Administrator from the Settlement Fund within twenty-one (21) business days after the Effective Date.

Unless you exclude yourself from the Settlement, you cannot sue or be part of any other lawsuit against Georgetown or the Released Parties about the issues in this case.  This specifically includes any claim for breach of contract or any tort, common law, or statutory claim arising out of or in any way allegedly related to Georgetown tuition, fees, and/or costs paid or incurred by or on behalf of any Settlement Class Member in connection with the Spring 2020 Semester.  Unless you exclude yourself, all of the decisions and judgments by the Court will bind you.

The Settlement Agreement is available here.  The Settlement Agreement provides more detail regarding the Releases and describes the Released Claims with specific descriptions in necessary, accurate legal terminology, so read it carefully.  If you have any questions, you can talk for free to the attorneys identified below who have been appointed by the Court to represent the Settlement Class, or you are welcome to talk to any other lawyer of your choosing at your own expense.

Cash Awards will be distributed after the Court grants Final Approval to the Settlement.  The Parties cannot accurately predict when (or whether) the Court will grant Final Approval to the Settlement, or whether there may be appeals from that order that take additional time to resolve, so please be patient.  After the Court grants Final Approval to the Settlement, and after any appeals are resolved, Cash Awards will be paid within 60 days.

Updated information about the case will be made available here, or you can call the Settlement Administrator at (877) 916-4174 or contact Class Counsel at the information provided below.

The Court has already granted a Motion for Preliminary Approval of Class Action Settlement.  A final hearing on the Settlement, called a “final approval” or “fairness” hearing, will be held to determine the fairness of the Settlement.  At the Final Approval Hearing, the Court will also consider whether to make final the certification of the Settlement Class for settlement purposes, hear any proper objections to the Settlement, and consider requests for an award of attorneys’ fees and expenses, and Service Awards for the Lead Plaintiffs.  The Court will hold the Final Approval Hearing on November 21, 2024, at 10:00AM ET, at the U.S. District Court for the District of Columbia, 333 Constitution Avenue N.W., Washington D.C. 20001.  The date and time of the Final Approval Hearing are subject to change by Court Order, and the hearing may be conducted remotely.  Any changes, including instructions for how Settlement Class Members may attend the hearing if it is conducted virtually or by telephonic means, will be posted on the settlement website, and on the Court’s docket on PACER at http://ecf.dcd.uscourts.gov.

If the Settlement is given Final Approval, the Court will not make any determination as to the merits of the claims or defenses at issue.  Instead, the Settlement’s terms will take effect and the Lawsuit will be dismissed on the merits with prejudice.  Both sides have agreed to the Settlement to achieve an early and certain resolution to the Lawsuit, so it provides specific and valuable benefits to the members of the Settlement Class.

If the Court does not grant Final Approval of the Settlement, or if Final Approval is reversed on appeal, or if the Settlement does not become final for some other reason, Plaintiffs, Georgetown, and Settlement Class Members will be in the same position as they were before the execution of the Settlement, and the Settlement will have no legal effect, no class will be certified (conditionally or otherwise), and Plaintiffs and Georgetown will continue to litigate the Lawsuit.  There can be no assurance that, if the Settlement is not approved, the Settlement Class will recover more than is provided in the Settlement, or indeed, anything at all.

This Notice is only a summary of the proposed Settlement.  More details are in the Settlement Agreement which, along with other documents, can be obtained by clicking here.  If you have any questions, you can also call the Settlement Administrator at (877) 916-4174 or Class Counsel at the numbers or email addresses set forth below.  Besides the documents available on the case website, all pleadings and documents filed in court may be reviewed or copied in the Office of the Clerk.

Please do not contact the Judge or the Clerk of the Court or Georgetown University about this case.  They cannot give you advice on your options.

The Court has approved these attorneys to represent the Settlement Class.  They are called “Class Counsel.”

You will not be charged for these lawyers.  If you want to be represented by your own lawyer, you may hire one at your own expense.

Michael Tompkins
Leeds Brown Law, P.C.
One Old Country Road, Suite 347
Carle Place, NY 11514
Tel: (516) 873-9550
Mtompkins@leedsbrownlaw.com

Anthony Alesandro
Leeds Brown Law, P.C.
One Old Country Road, Suite 347
Carle Place, NY 11514
Tel: (516) 873-9550
aalesandro@leedsbrownlaw.com