CLAIM FAQS

This page provides general information regarding the Willows Class Action Settlement.

Eligibility FAQs

What is the lawsuit about?

This case is pending in the United States District Court for the Eastern District of Louisiana. The full name of the action is Cierra Rousseau-Dobard, et al. versus MOF-Preservation of Affordability Corp., et al., on the docket of the United States District Court for the Eastern District of Louisiana bearing civil action no. 2:23-cv-01433.

The Plaintiffs in this lawsuit allege that they have been damaged by the living conditions at The Willows apartment complex between January 1, 2014 and June 11, 2025. More specifically, the Plaintiffs allege that they experienced water leaks, mold, rodent infestation, dilapidated and failing building structures, lack of maintenance, severe crime, lack of security, and lack of cleanliness. Plaintiffs assert claims for breach of contract.

Defendants vigorously deny Plaintiffs’ allegations of breach of contract and negligence and deny that any conduct challenged by Plaintiffs caused any damage whatsoever and have asserted a number of defenses to Plaintiffs’ Claims.

The Court has not issued a final ruling on Plaintiffs’ Claims. Plaintiffs and Defendants have agreed to the Settlement to avoid the risk and expense of further litigation. Plaintiffs believe that their Claims have merit, but that the Settlement is fair, reasonable, and in the best interests of the members of the Class given the risk and expense of further litigation.

Why is this a Class Action?

In a Class Action, one or more people, called Class Representatives, sue on behalf of other people who have similar claims. All these people together are called a “Class” and the individuals are called “Class Members.” One court decides all the issues in such a Class Action lawsuit for all Class Members, except for those who exclude themselves from the Class. In a Class Action, the Court has a responsibility to assure that prosecution and resolution of the Class Claims by the Class Representatives and their attorneys is fair. In this lawsuit, the Class Representatives are asking the Court to decide the issues for all persons who sustained damages as a direct result of the living conditions at The Willows apartment complex at any time between January 1, 2014 and June 11, 2025.

Why is there a proposed settlement?

The Court did not rule in favor of either party. Instead, the Parties agreed to a Settlement to avoid the expense and risks of continuing the lawsuit. The Class Representatives and their attorneys think the Settlement is best for all members of the Class.

How do I know if I'm a part of the Class?

The Class includes: All individuals who leased residential property at The Willows apartment complex and sustained damages as a direct result of the living conditions at The Willows apartment complex at any time between January 1, 2014 and June 11, 2025.

This proposed settlement addresses rental reimbursements to all lessees and people who leased and/or occupied pursuant to a lease at The Willows apartment complex and sustained damages as a direct result of the living conditions at The Willows apartment complex at any time between January 1, 2014, and June 11, 2025. Regardless of the number of individuals occupying a single unit at The Willows apartment complex, only one claim for rental reimbursement may be made per household by the individual whose name was on the lease as being responsible for rental payments or his/her representative. This is because only one rental payment was required to be paid during any given rental period, regardless of how many people occupied an apartment at one time.

If this describes you, you are automatically a member of the Class unless you exclude yourself by following the steps for exclusion described below.

Persons who are members of the Class and do not exclude themselves will be bound by the Settlement, if approved by the Court, whether or not they submit a Proof of Claim Form, and will be prevented from bringing other Claims covered by the Settlement. Those who exclude themselves from the Class will not be bound by the Settlement and will not receive any payments from the Settlement.

In order to receive a monetary award, you must submit a valid Proof of Claim Form UNLESS you leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 AND you received this Notice addressed to you via U.S. Mail. If you leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 AND you received this Notice addressed to you via U.S. Mail, you do not have to do anything more and you will receive a monetary award if the Court finally approves the Settlement.

If you DID NOT lease an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025, AND you DID NOT receive this Notice addressed to you via U.S. Mail, you must submit a Proof of Claim Form by the deadline stated herein in order to receive a monetary award.

What does the proposed settlement provide?

The Proposed Settlement provides benefits to members of the Settlement Class. It was negotiated between Plaintiffs and Defendants, through their attorneys, and has been preliminarily approved by the Court. The Settlement terms provides that the Defendants will establish a non-reversionary $3,200,000 Settlement Fund that provides payments to Settlement Class Members of monetary relief to be divided between: (1) each individual who leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 AND received this Notice addressed to them via U.S. Mail and (2) each individual who leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 who does not meet the criteria of category (1) but who submits a Proof of Claim Form within the time limitations set forth herein.

The monetary relief will be provided in progressive amounts depending on which year(s) each Class Member leased an apartment at The Willows apartment complex.

From the Settlement Fund, $150,000 will be distributed to Class Members who leased an apartment at The Willows apartment complex between January 1, 2014 and December 31, 2017, with payment amounts increasing as living conditions deteriorated over time—lessees from 2017 will receive greater compensation than lessees from 2016, and lessees from 2016 will receive greater compensation than lessees from 2015, and so on.

From the Settlement Fund, $3,000,000 will be distributed Class Members who leased an apartment at The Willows apartment complex between January 1, 2018 and June 11, 2025, with payment amounts increasing as living conditions deteriorated over time—lessees from 2025 will receive greater compensation than lessees from 2024, and lessees from 2024 will receive greater compensation than lessees from 2023, and so on.

At this time, the amount of the payment is estimated to be in the range of $7.09 to $177.90 per unit, per month of rental

The remaining $50,000 in the Settlement Fund will be used to pay expenses associated with administering the settlement.

When will I receive my Settlement benefits?

Settlement benefits will be available only if the Settlement is finally approved by the Court. The Parties anticipate that the Court will hold a Fairness Hearing on July 9th 2026, to decide whether to approve the Settlement. If the Court approves the Settlement and appeals or post-judgment motions are filed, the Settlement does not become Final until all such appeals and post-judgment motions are resolved. It is always uncertain how long such motions and appeals, if any, might take – they can take many months or longer. You should check the Settlement Website at https://www.willowsclassaction.com/dates-and-deadlines for updates on the status of the Settlement and applicable deadlines. Please be patient.

How do I submit a Claim form?

Unless you leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025, and you received this Notice addressed to you via U.S. Mail, you must complete and submit a Proof of Claim Form if you wish to receive a monetary award. To submit the Proof of Claim Form, you must do one of the following: (i) complete an electronic Proof of Claim Form and submit it to the Claims Administrator via the Settlement Website at https://www.willowsclassaction.com/submit-claim on or before July 24th 2026; or (ii) complete a paper Proof of Claim Form and send it to the Claims Administrator via fax to 5043210576, via United States mail, postage prepaid to 1100 Poydras St. Suite 1200 New Orleans LA 70163, or via e-mail to jacob@hermanandyoung.com by July 24th 2026. You can call (504) 581-7068 to request a Proof of Claim Form be mailed to you.

The remaining $50,000 in the Settlement Fund will be used to pay expenses associated with administering the settlement.

Who is included in the Settlement?

The Settlement includes all current and former residents of The Willows complex who resided at the property during the Class Period. This includes individuals named on a lease agreement as well as other household members who lived at the address and sustained damages as a direct result of the living conditions.

What is the Class Period and applicable addresses?

The Class Period ends on June 11, 2025. Anyone who resided at the Willows complex in New Orleans within the dates specified in the Official Notice is eligible to participate. Eligibility is verified based on official residency records and documentation during this time frame.

What happens if I do nothing at all?

If you do nothing you will remain a Class Member and all of the Court’s orders pertaining to the Class will apply to you. You won’t be able to sue, or join a new lawsuit, against any of the Released Parties for any damages that you may have sustained as a direct result of the living conditions at The Willows apartment complex at any time between January 1, 2014 and June 11, 2025.

If you leased an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 AND you received this Notice addressed to you via U.S. Mail, you do not have to do anything more and you will receive a monetary award if the Court finally approves the Settlement.

If you DID NOT lease an apartment at The Willows apartment complex between January 1, 2014 and June 11, 2025 AND you DID NOT receive this Notice addressed to you via U.S. Mail, you must submit a Proof of Claim Form by the deadline stated herein in order to receive a monetary award. Proof of Claim Forms can be obtained by contacting Class Counsel or visiting the website www.willosclassaction.com or calling 5042385050.

Do I have a lawyer in this case?

Yes, the Court has appointed the following attorneys as Class Counsel to represent the Class:

Megan Kiefer
Kiefer & Kiefer
1100 Poydras St., Suite 1300
New Orleans, LA 70163
Telephone: (504) 828-3313
Telefax: (504) 828-0024
megan@kieferlaw.com

Jacob D. Young
Herman & Young
1100 Poydras St. Suite 1200
New Orleans, LA 70163
Telephone: (504) 581-7068
Facsimile: (504) 321-0576
jacob@hermanandyoung.com

You will not be charged for this lawyer. You are welcome to call this lawyer with any questions about the lawsuit or Settlement, or to otherwise discuss further the Settlement.

You may also consult your own lawyer at your own expense.

How much will the lawyer for the Settlement Class be paid and how will they be paid?

Class Counsel will ask the Court to approve payment of attorneys’ fees of no more than $787,500.00 and expenses of no more than $30,000. Class Counsel also will ask the Court to award each of the named plaintiffs who were deposed $25,000 each, and the remaining named plaintiffs $3,500 each for their time and effort pursuing this matter on behalf of the Class. These payments will come out of the Settlement Fund. Class Counsel will file their fee application at least ten (10) business days before the deadline for objecting to the Proposed Settlement.

When and where will the Court decide whether to approve the Proposed Settlement?

The Court will hold a Final Fairness Hearing on July 9th, 2026 at the Hale Boggs Federal Building and Courthouse which is located at 500 Poydras Street in New Orleans, Louisiana, or by remote or virtual means, as ordered by the Court. This hearing date may be moved, cancelled, or otherwise modified, so please regularly check the following for further details: (i) the Settlement Website at www.willowsclassaction.com; (ii) or call 504 581-7068;or (iii) the Court docket in this case by visiting the office of the Clerk of the Court for the United States District Court for the Eastern District of Louisiana, 500 Poydras Street, New Orleans, Louisiana 70130.

At the Final Fairness Hearing, the Court will consider all timely and properly raised objections, if any, and will consider whether the Settlement is fair, reasonable, and adequate to the Class. The judge may listen to people who have timely and properly objected to the Settlement and requested to speak at the hearing. The judge may also decide how much to award to Class Counsel for their fees and expenses. At or after the hearing, the judge will decide whether to approve the Settlement. We do not know how long these decisions will take.

Do I have to come to the Final Fairness Hearing?

No, you don’t have to come to the hearing. Class Counsel will answer any questions the Court may have. But you and/or your lawyer are welcome to come at your own expense. If you timely and properly file and serve a written objection, you don’t have to come to the hearing for the judge to consider it.

Can I speak at the hearing?

Yes, you may, but only if you timely and properly file and serve a written objection and Notice of Appearance, as set forth in response to Question No. 14 above. You cannot speak at the hearing if you exclude yourself from the Class.

Are more details about the lawsuit and the Settlement available? If so, where can I access any additional information?

Opt-Out or Object

How do I exclude myself from the Settlement Class?

To exclude yourself from the Settlement Class, you must timely send an electronic or written request to be excluded to the Claims Administrator that contains all of the following information:

Your name, current address, and telephone number;

A statement that you want to be excluded from the case Cierra Rousseau-Dobard, et al. versus MOF-Preservation of Affordability Corp., et al., on the docket of the United States District Court for the Eastern District of Louisiana bearing civil action no. 2:23-cv-01433, that you do not wish to be a Class Member, and that you want to be excluded from any judgment entered in this case;

Your signature (or your lawyer’s signature).

To submit a request to be excluded from the Class, you must do one of the following: (i) complete an electronic request and submit it to the Claims Administrator via the Settlement Website at www.willowsclassaction.com on or before June 9th 2026; or (ii) complete a written request to be excluded and send it to the Claims Administrator at 1100 Poydras St. Suite 1200 New Orleans LA, 70163 by June 9th 2026.

Any request for exclusion sent by United States mail must be postmarked on or before June 9th 2026.

What am I giving up to stay in the Class?

If you leased an apartment at The Willows apartment complex and sustained damages as a direct result of the living conditions at The Willows apartment complex at any time between January 1, 2014 and June 11, 2025, and if you do not timely exclude yourself from the Class as outlined below, you are automatically a Class Member and you will be included in the Class.

If you stay in the Class, you cannot sue or be part of any other lawsuit against Defendants about the Claims in this lawsuit. In addition, if you stay in the Class, all of the Court’s orders pertaining to the Class will apply to you.

How do I tell the Court I don’t like the Proposed Settlement?

If you are a member of the Class and don’t exclude yourself, you can object to the Settlement or any part of it by filing and serving a written objection as explained here. You can ask the Court to deny approval of the Settlement by filing an objection. You cannot ask the Court to order a larger settlement; the Court can only approve or deny the Proposed Settlement. If the Court denies approval, no Settlement Payments will be made and the parties to the lawsuit will return to their positions before Settlement. If that is what you want to happen, you must object.

To object, you must file your written objection with the Court no later than June 9th 2026. You must also send your objection to Class Counsel and Counsel for Defendants, postmarked no later than June 9th 2026.

Clerk of Court, United States District Court, Eastern District of Louisiana, 500 Poydras Street, New Orleans, Louisiana 70130.

Class Counsel: Megan Kiefer, Kiefer & Kiefer, 1100 Poydras St., Suite 1300, New Orleans, LA 70163. Telephone: (504) 828-3313. Telefax: (504) 828-0024. megan@kieferlaw.com.

Jacob D. Young, Herman & Young, 1100 Poydras St, Suite 1200, New Orleans, LA 70163. Telephone: (504) 581-7068. Facsimile: (504) 321-0576. jacob@hermanandyoung.com.

Counsel for Defendants: Emily Eagan, Laborde Siegel, L.L.C., 701 Poydras Street, Suite 4800, New Orleans, Louisiana 70139. Telephone:(504) 561-0400. Facsimile:(504) 561-1011.

Your objection must include your full name, telephone number, home address, email address, any address or other proof of membership in the Class. In addition to the above, your objection must state the reasons why you are objecting, and whether you intend to appear in Court at any Final Fairness Hearing either with or without a separate attorney and be signed by you or your attorney. If you have documents supporting your objection, you must attach them to your letter. If you intend to call witnesses at the Final Fairness Hearing, you must identify them in your letter.

If you wish to appear and speak at the Final Fairness Hearing, you must file a Notice of Appearance with the Court and mail it to Class Counsel and Defendants’ Counsel no later than ten (10) business days before the hearing.

Claim Process FAQs

This page provides informational answers to common questions regarding the claim submission process. This information is provided for reference purposes only and does not constitute legal advice.

How to Submit a Claim

To participate in the settlement, direct residents must submit a completed Claim Form by the deadline. You may use any of the following methods:

Online Portal: Use the secure web form on the Settlement Website to type your information directly.
Document Upload: Scanned forms and supporting documents can be uploaded via the secure portal in PDF or JPEG format.
U.S. Mail: Send physical forms to the Settlement Administrator address listed on the official notice.

If multiple individuals were listed on a single lease, each individual must submit their own claim form. If you no longer have your lease, you may provide alternative documents such as government mail, utility bills, or bank statements showing your address during the class period.

Settlement Status

The Court has not yet ruled on whether to approve the Settlement. The Class Period ends June 11, 2025. Final approval hearings and payment processing timelines are subject to change by the Court. Most claimants will receive updates regarding their payment status after the final hearing occurs.

Important Warnings

Please do not call the Court or the Clerk of the Court for information about this settlement. They cannot provide legal advice or claim updates. Official notices and important updates will be posted regularly to this Settlement Website.

Eligibility

Timelines

Who is included in the Settlement?
Current and former residents of The Willows who lived at the address and sustained damages as a direct result of the living conditions during the Class Period are included. Sustained damages refers to specific losses, health impacts, or financial costs caused by the infrastructure failures and maintenance issues documented in the settlement.

Key Deadlines
The class period is currently set to end on June 11, 2025. All deadlines, including those for filing objections or opting out, are listed on the official notice. Payment distribution typically occurs several months after the Court grants final approval, following a mandated review of all submitted claims for accuracy.

WILLOWSCLASS ACTION

WILLOWS CLASS ACTION