CLASS ACTION

COMPLEX LITIGATION DOCKET - JUDICIAL DISTRICT OF WATERBURY

DOCKET NO. UWY-CV-22-6072520S

This matter is pending in the Superior Court of the State of Connecticut, on the Complex Litigation Docket, Judicial District of Waterbury. The case caption is Wayne Jones, Individually and on behalf of all other similarly situated individuals, v. Redding Golf and Country Club, LLC, as successor in interest to OLD CLUB, INC. formerly known as REDDING COUNTRY CLUB, INC., Docket No. UWY-CV-22-6072520-S. Public judicial filings are available electronically on the State of Connecticut Judicial Branch website: www.jud.ct.gov.

If you purchased and hold a Capital Certificate For Special Assessment (“Capital

Certificate”) from Redding Golf and Country Club, LLC, or its predecessor, Old Club,

Inc., formerly known as Redding Country Club, LLC (“RCC”), in the amount of $8,500,

you resigned from RCC, made a request for payment to RCC under the Capital

Certificate, the principal amount of which has not been repaid to you, your Capital

Certificate number appears on a certain list designated by the Court

Plaintiff was a member of RCC. Plaintiff alleges that, on about September 25, 1998, RCC’s Board of Managers approved a resolution whereby each member of RCC was issued a Capital Certificate For Special Assessment (“Capital Certificate”) in the face amount of $6,000 in exchange for the payment of this sum to RCC. Plaintiff further alleges that, on or about March 22, 2001, RCC increased the amount of the Capital Certificates in exchange for additional payments from all members of RCC and new Capital Certificates in the face amount of $8,500 were issued and the previously issued Capital Certificates were deemed to be canceled. Plaintiff maintains that he resigned from RCC in 2008, was entitled to repayment on his Capital Certificate and RCC failed to do so. 

The Plaintiff has initiated this action on behalf of himself and other similarly affected individuals, seeking monetary damages for breach of contract, breach of the covenant of fair dealing, fraudulent misrepresentation, and fraudulent concealment. 

RCC denies all of these claims. RCC has asserted a number of defenses to Plaintiff’s claims including that it had and has no contractual or statutory duty to repay the Capital Certificates and Plaintiff and other class members’ claims are barred due to a lapse in time. In particular, RCC filed an Answer to the Plaintiffs’ Amended Complaint specifically denying each of the Plaintiff’s allegations as to breach of contract, breach of the covenant of fair dealing, fraudulent misrepresentation, and fraudulent concealment. RCC intends to present evidence to refute the Plaintiff’s allegations as noted above as well as evidence refuting the Plaintiff’s claimed damages. In addition, RCC has asserted legal defenses to the Plaintiff’s claims known as “Special Defenses.”   

The Plaintiffs' First Amended Complaint dated October 19, 2022 (Docket Entry 106.00) and RCC’s Answer and Special Defenses dated August 18, 2023 (Docket Entry 116.00) are available on the Connecticut Judicial Branch website (www.jud.ct.gov) or from the Clerk of the Court.

This Notice is to inform you that the Connecticut Superior Court (the “Court”) has preliminarily approved

a Proposed Settlement of the Lawsuit (the “Proposed Settlement”) which provides payments to eligible

individuals.

 This Proposed Settlement, if approved, will affect you if you are a Class Member. If the

Proposed Settlement is approved and you do not exclude yourself from this class action, you will receive a sum of money if you qualify as explained herein. If you purchased and hold a Capital Certtificate from RCC, in the amount of $8,500, you resigned from RCC, made a request for payment to RCC under the Capital Certificate, 

the principal amount of which has not been repaid to you,

your Capital Certificate number appears on a certain list designated by the Court, you must fill

out a Payment Directive Form to receive such benefits.

YOUR RIGHTS AND OPTIONS – AND THE DEADLINES TO EXERCISE THEM – ARE

EXPLAINED IN THIS NOTICE. PLEASE READ THIS NOTICE CAREFULLY. IF YOU WOULD

LIKE ADDITIONAL INFORMATION, YOU MAY CONTACT LEGAL ADMINISTRATION AS

NOTED BELOW

YOUR LEGAL RIGHTS AND OPTIONS IN THIS PROPOSED SETTLEMENT

The lawyer for the Plaintiffs and the Class is: 

Anthony J. LaBella, Esq.

Anthony J. LaBella, Esq. P.C.

1100 Kings Highway East

Suite 2B

Fairfield, CT 06825

Tel. 203-515-1870

www.ajlesq.com

The Court has appointed this lawyer to represent the Class Members. The lawyer is called Class Counsel. More information about Class Counsel can be found at https://ajlesq.com. You can also contact Class Counsel via e-mail at: ReddingClassaction@ajlesq.com or anthony@ajlesq.com

  If Class Counsel obtains money or benefits for the Class, they may ask the Court to award their fees and expenses. You do not have to pay these fees and expenses directly. If the Court awards Class Counsel their fees and expenses, they would be deducted from any money obtained for the Class or paid separately by RCC (if ordered by the Court).

DEADLINES ARE IMPORTANT PLEASE READ THE LONG FORM NOTICE OR CONTACT CLASS COUNSEL IF YOU HAVE ANY QUESTIONS