LUTHER BOND and DAVID FLYTE, on behalf of themselves and all others similarly situated, v WASTE MANAGEMENT OF PENNSYLVANIA, INC. and GRAND CENTRAL SANITARY LANDFILL, INC.,

The Action alleges that Defendants created a nuisance by releasing noxious odors from the Grand Central Sanitary Landfill resulting in the loss of use and enjoyment of property of the homes within the Class Area.

In a class action, one or more people or entities called “class representatives” are appointed by the court to sue on behalf of themselves and other persons or entities who have the same or similar claims. In this case, the Court appointed Luther Bond and David Flyte as the “Class Representatives.” The Class Representatives and those they represent together are called a “class” or “class members.” Those who filed the suit are called “plaintiffs” and those being sued are called “defendants.” One court proceeding resolves the issues and claims for all class members, except for those who exclude themselves, or “opt out,” from the Class.

The Class Representatives seek money to compensate Class Members for the losses they allegedly suffered because of Defendants’ conduct, including loss of use and enjoyment of their property; attorneys’ fees and case costs; as well as pre-judgment and post judgment interest.  Damages may be sought based on how many hours during the years of 2017 through 2019 that each homeowner or renter experienced noxious odors based upon expert testimony.  Homeowners and renters who experienced more frequent odors may obtain more compensation than class members who experienced the odors less frequently.

No money or benefits are available in this Action now because the Court has not yet decided whether Defendant(s) did anything wrong, and the two sides have not settled the case. There is no guarantee that any money or benefits ever will be obtained. If they are, you will receive a notice describing how to receive a share of any recovery in which you may be eligible to participate.

You are a member of the Class if you if you owned or rented a residential property in the Class Area between January 1, 2017 and December 31, 2019.

There are also some people and entities that are excluded from the Class by definition. The excluded persons and entities are each of Defendant(s)’ officers, directors, agents, employees, and members of their immediate families, and the judicial officers to whom this case is assigned, their staff, and the members of their immediate families.

If you are still not sure whether you are included in the Class, you can get help by calling or writing to Class Counsel in this case: [email protected] 1-888-766-7538.

You must decide whether to stay in the Class or opt out of it.

If you stay in the Class, you will be permitted to share in any recovery that may be awarded in this Action if you suffered compensable losses, subject to the terms of any plan of allocation that may be approved by the Court. If you decide to stay in the Class, you will also be legally bound by all of the determinations, including orders and judgments, that the Court has made or will make in this Action, even if there is no recovery.

You do not have to do anything at this time to stay in the Class.

If you opt out of the Class (by stating in writing that you do not want to be included in the Class in this Action in accordance with the procedures set forth in this Notice), you will give up the right to participate in any recovery that may be achieved in this Action. But you will keep any rights you may currently have to sue Defendant(s) regarding the legal claims at issue in this lawsuit. If you opt out of the Class, you will also not be bound by the Court’s determinations in this Action and will no longer be represented by Class Counsel.

To exclude yourself from the Class, you must send a letter by regular mail saying that you want to be excluded from the Class in the following action: Bond, et al. v. Waste Management of Pennsylvania, Inc., et al., Case No.: C-48-CV-2019-02017. Be sure to include your name, current address, property address in the Class Area, email address, and telephone number, and sign the letter. Your exclusion request must be received no later than June 21, 2025 and sent to Class Counsel at:

John E. Kotsatos, Esquire

Kotsatos Law PLLC

717 Washington Street

Easton, PA 18042

You cannot exclude yourself by phone or email. If you make a proper request for exclusion, you will not be legally bound by anything that happens in this Action.

The Court has appointed lawyers to represent you and other Class Members. These lawyers are called “Class Counsel.” Lawyers from the following law firm are representing the Class:

John E. Kotsatos, Esquire of Kotsatos Law PLLC

Email: [email protected]

Phone: 484-403-6214

Jonathan B. Nace, Esquire (Admitted pro hac vice) of Nidel & Nace, PLLC

Email: [email protected]

Phone: 202-780-5153

Mark L. Minotti, Esquire of Minotti Law Offices

Email: [email protected]

Phone: 610-258-0455

You will not be separately charged for these lawyers, or for the services of any other counsel representing the Class.

If a recovery is obtained for the Class, Class Counsel will seek an award of attorneys’ fees as a percentage of the value of any recovery or award and for reimbursement of litigation expenses that have been incurred in pursuing the Action. Class Counsel may also ask the Court to approve a reasonable service award for the Class Representatives or other plaintiffs who assisted in prosecuting the Action.

You do not need to hire your own lawyer. However, you are free to hire your own lawyer at your own expense. If you hire a lawyer to speak for you or to appear in Court, your lawyer must file a Notice of Appearance.

For more information regarding this class action, please visit the Important Documents page of this website which includes the full notice, important dates and court documents.

Complete copies of public pleadings, Court rulings and other filings are available for review and copying at the Northampton County Prothonotary of the Court of Common Pleas of Northampton County located at 669 Washington St, Easton, PA 18042. Kindly refrain from contacting the Court, Judge Beltrami, the Clerk of the Court, Defendants, or Defendants’ Counsel for additional information. They cannot answer any questions or discuss the Action.