To: Individuals whose vehicles were non-consensually towed from one of the parking lots located at 1709 Saw Mill Run Boulevard, Pittsburgh, PA 15210; 925 East Carson Street, Pittsburgh, PA 15203; 2401 East Carson Street, Pittsburgh, PA 15203; 20 Bailey Avenue, Pittsburgh, PA 15211; 304 Virginia Avenue, Pittsburgh, PA 15211; 3439 W Run Road, Homestead, PA 15210 by TAG Towing and Collision.

A settlement has been proposed to resolve a lawsuit against CoGo’s Co. (“CoGo’s” or “Defendant”) brought by Christopher Zimmerman, Corey Mizell, Stephanie Dawson, Mike Lewis, and Christopher Grabovski (“Plaintiffs” or “Settlement Class Representatives”), on behalf of themselves and all persons similarly situated. The lawsuits, referred to as in the matters captioned: Christopher Grabovski, individually and on behalf of all others similarly situated v. Realty Income Corporation; CoGo’s Co.; and Brian Haenze d/b/a Auto Gallery & Accessories and as Tag Towing and Collision, GD-18-012294 and Christopher Zimmerman, Corey Mizell, Stephanie Dawson, and Mike Lewis individually and on behalf of all others similarly situated v. Sony Lazarevic, Zoran Lazarevic, Sylvia Duda, CoGo’s Co., and Brian Haenze d/b/a Auto Gallery & Accessories and as Tag Towing and Collision, GD-18-012068, in the Court of Common Pleas of Allegheny County, Pennsylvania, assert claims on behalf of a class of individuals relating to tows from parking lots located at 1709 Saw Mill Run Boulevard, Pittsburgh, PA 15210; 925 East Carson Street, Pittsburgh, PA 15203; 2401 East Carson Street, Pittsburgh, PA 15203; 20 Bailey Avenue, Pittsburgh, PA 15211; 304 Virginia Avenue, Pittsburgh, PA 15211; and 3439 W Run Road, Homestead, PA 15210 (collectively all of the foregoing are referred to as the “Parking Lots”). Plaintiffs allege that following non-consensual tows from the Parking Lots by Brian Haenze d/b/a Auto Gallery & Accessories and as Tag Towing and Collision (“Tag Towing”), Plaintiffs were charged amounts exceeding the maximum allowable as set forth under the Pittsburgh Code of Ordinances and Pennsylvania law and assert that CoGo’s and/or Tag Towing violated the Pennsylvania Unfair Trade Practices and Consumer Protection Law (“UTPCPL”), 73 Pa. Stat. § 201-1, et. seq., the Pennsylvania Fair Credit Extension Uniformity Act (“PaFCEUA”), 73 Pa. Stat. § 2270.1, et seq., and various common law causes of action. CoGo’s denies these allegations, denies any wrongdoing, and denies that it would be found liable to Plaintiffs and/or the Settlement Class Members.

• Subject to Court approval, an agreement has been reached to settle the lawsuit through a series of arms’-length negotiations between Plaintiffs’ and CoGo’s respective attorneys without the admission of any alleged liability by any person or entity – which liability is expressly denied. On May 6, 2024, the Court granted Preliminary Approval of the Settlement Class consisting of all members of the following settlement class:

  All owners or operators whose vehicle of any type (including any passenger cars, light trucks, or motorcycles, and scooters) were non-consensually towed from the Parking Lots by Tag Towing within the Relevant Period, and who, as a result were charged and paid a fee in excess of the limits identified in 5 Pittsburgh Code § 525.05 and otherwise pursuant to Pittsburgh Code.

• Under the Class Settlement Agreement and Release (“Settlement”), payment of $35,000.00 will be made into a Settlement Fund, out of which the Settlement Administrator will make payments to Settlement Class Members. The methods that will be used to distribute these funds to Settlement Class Members are described in detail in the Notice. The costs of notice and settlement administration and court-approved service awards of $1,000 for each Settlement Class Representative will also be paid from the Settlement Fund.
• Further, if approved by the Court, payment of up to $69,000.00 will be made relating to fees, costs, and expenses to attorneys for the Settlement Class. These payments will be made separate from the Settlement Fund that will be used to pay the Settlement Class Members.