SHY V NAVISTAR INTERNATIONAL CORP.
CASE NO. 3:92-CV-0333-WHR (S.D. OHIO)
Important Case Documents
Final Order
Complaint
First Amended Complaint
Second Amended Complaint
Intervenor Complaint for Breach of Settlement Agreement and for Injunctive Relief
Amended Complaint
Complaint for Enforcement of Settlement Agreement
Krzysiak Complaint
Class Representatives’ Unopposed Motion for Preliminary Approval of Class Settlement and Approval of Amendments to the Supplemental Benefit Program
Memorandum in Support
Ex. 1 – Class Settlement Agreement
Ex. A – Subaccount A Resolution
Ex. B – 1993 Consent Decree (with Modifications Shown in Redline)
Ex. C – Modified Consent Decree (Clean Version)
Ex. D – Profit Sharing Settlement Agreement
Ex. E – Krzysiak Action Settlement Agreement
Ex. F – Class Releases
Ex. G – Long-form Notice (Mail)
Ex. H – Email Noticehy Se
Ex. I – Publication Notice
Ex. 2 – Proposed Timeline
Ex. 3 – Proposed Order Granting Motion (Granted on 1/10/2022)
Ex. 4 – Declaration of Edward Scallet (Outside Counsel for SBC)
Ex. 5 – Declaration of Donn Viola (SBC Committee Chair)
Ex. 6 – Declaration of Jonathan Cocks (Accountant for SBC)
Ex. 7 – Declaration of Stuart I. Wohl (Consultant to SBC)
Ex. 8 – Declaration of Wayne Krzysiak (SBC Member, Plaintiff in Krzysiak Action)
Ex. 9 – Declaration of Michael LaCour (Former SBC Member, Plaintiff in Krzysiak Action)
Ex. 10 – Declaration of W.B. Markovits (Class Counsel)
Ex. 11 – Declaration of Carl Potts (Class Representative)
Ex. 12 – Declaration of Miller Rodgers (Class Representative)
Ex. 13 – Declaration of Richard Zounes (Class Representative)
Ex. 14 – Declaration of Fred Cortright (Class Representative)
Ex. 15 – Declaration of Robert Bergmann (Class Representative)
Ex. 16 – Declaration of Curt A. Kramer (Navistar Senior VP and General Counsel)
Ex. 17 – Declaration of Natasha S. Fedder (ERISA Counsel Retained by Class Counsel)
UAW Response in Support of Class Representatives’ Unopposed Motion
Order Granting Class Representatives’ Unopposed Motion for Preliminary Approval of Class Settlement and Approval of Amendments to the Supplemental Benefit Program
Unopposed Motion to Further Modify Consent Decree
Memorandum in Support
Ex. A – Consent Decree with Further Modifications
Ex. B – Proposed Order
UAW Response to Unopposed Motion to Further Modify Consent Decree
Order Granting Unopposed Motion to Further Modify Consent Decree
Class Representatives’ Unopposed Motion for Final Approval of Class Action Settlement Agreement and Attorney Fees and Expenses
Memorandum in Support
Declaration of Brian R. Delphey (Navistar Benefits Director)
Declaration of W. B. Markovits (Class Counsel)
Declaration of Carl Potts (Class Representative)
Declaration of Miller Rodgers (Class Representative)
Declaration of Robert Bergmann (Class Representative)
Declaration of Fred Cortright (Class Representative)