Frequently Asked Questions

Plaintiffs Jed Behar and Alisa Behar filed this lawsuit on behalf of themselves and a class of property owners in the Class Area. Plaintiffs allege that Defendants are responsible for certain contaminants in the soil and groundwater in the Class Area, including but not limited to trichloroethylene (TCE) and perchloroethylene (PCE). Plaintiffs allege that the contamination was caused in the late 1960s to early 1970s by alleged legal predecessors of Defendants. Plaintiffs asserted claims of negligence, private nuisance, and trespass. Plaintiffs claim that the presence of the alleged contamination has caused property values in the Class Area to decrease and that homes in the Class Area require the installation of vapor-intrusion mitigation measures (“Mitigation Measures”).

Defendants deny these allegations and contend, among other things, that they are not responsible for any alleged contamination, that there is no evidence of any loss of property value in the Class Area, that there is no evidence of the presence of contamination from its alleged predecessor’s operations in any homes—or of any measurable risk that such contamination will ever be present in any homes—in the Class Area, and that there is no evidence of any need for Mitigation Measures at any property. Defendants also contend that the plume of contaminated groundwater in the Class Area has been reduced and will continue to be reduced, and that their remediation and clean-up efforts have been successful. The Court has not decided who is right.

In a class action, one or more people, called Class Representatives (in this case, Jed Behar and Alisa Behar), sue on behalf of others who have similar claims. All these people together are a “Class” or “Class Members.” One court resolves the issues for all Class Members, except for those who exclude themselves from the Class. On July 1, 2024, the Court certified two classes in this case (Dkt. 175). For purposes of this Settlement only, the Court will be asked to certify a single Settlement Class as defined in Question 5 of the Settlement Notice or seen below in Question 3.

If you received the Settlement Notice in the mail or by email without requesting it, public records show you may be a current or former owner of a single-family home or townhome in the Class Area. You are a member of the Settlement Class if the following definition applies to you:

Settlement Class: All persons who own a single-family home or townhome within the Class Area as of the date of notice of the settlement, as well as all persons who owned a single-family home or townhome within the Class Area as of July 1, 2024, but who have since sold their single-family homes or townhomes as of the date of notice of the settlement, excluding employees of Defendants.

A map of the Class Area can be found here. The Class Area is divided into three geographic sub-areas, and Settlement Class Members in each sub-area are entitled to different payment amounts under the Settlement (see Question 10 of the Settlement Notice). A list of addresses within the Class Area, organized by sub-area, is also available here. You can also search for your address to see if it falls within the Class Area here.

To qualify for a payment, you must submit a Claim Form, together with proof of ownership, to the Class Administrator. Read the instructions carefully, complete the Claim Form, include the required proof of ownership, sign it, and mail it (or submit it electronically through the File Online Claim Form tab using the Unique ID and PIN provided to you on the mailed Settlement Notice and Claim Form) so that it is postmarked or received no later than October 10, 2026.

Only Claim Forms submitted directly to the Class Administrator will be accepted. No Claim Form submitted to a third party (e.g., a claims aggregator) will be valid. If the Class Administrator receives a Claim Form from any third party, the Class Administrator will take steps to contact the claimant and explain how to submit a Claim directly.

The Court will hold a Final Approval Hearing on November 12, 2026, at 10:00 AM Pacific Time, to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals. It is always uncertain whether and when appeals can be resolved, and resolving them can take time, perhaps more than a year. Defendants are required to fund the Settlement Fund within 30 days after the Effective Date (as defined in the Settlement Agreement). The Class Administrator will then make reasonable efforts to issue payments to eligible Settlement Class Members within 45 days after the Effective Date.

Checks issued under the Settlement will remain valid for 180 days from the date of mailing. If your check is not cashed within that period, the Class Administrator will attempt to locate you and re-issue a check with a 90-day expiration. If you cannot be located within 180 days after the expiration of the original check, uncashed funds will be redistributed equally among Settlement Class Members who timely cashed their checks. After one redistribution, any remaining funds will be paid to a Court-approved cy pres beneficiary.

Payments to Settlement Class Members will be allocated as follows:

First, $100,000.00 of the Net Settlement Proceeds (as defined in Question 9 of the Settlement Notice) will be distributed equally among Settlement Class Members who owned a single-family home or townhome within the Class Area as of July 1, 2024, but who have since sold their home as of August 11, 2026 (“Former Owners”), and who submit timely and valid Claim Forms.

Second, the remaining Net Settlement Proceeds will be allocated among current homeowners within three geographic sub-areas:

• Sub-Area A (approximately 789 homes): 40% of the remaining Net Settlement Proceeds will be divided equally among Settlement Class Members who own these homes as of the date of this Notice and submit timely and valid Claim Forms.
• Sub-Area B (approximately 727 homes): 28% of the remaining Net Settlement Proceeds will be divided equally among Settlement Class Members who own these homes as of the date of this Notice and submit timely and valid Claim Forms.
• Sub-Area C (approximately 1,778 homes): 32% of the remaining Net Settlement Proceeds will be divided equally among Settlement Class Members who own these homes as of the date of this Notice and submit timely and valid Claim Forms.

Based on conservative estimates and assumptions about administrative costs, attorneys’ fees and costs, service awards, and the number of Settlement Class Members who submit valid Claim Forms, Class Counsel estimates that each eligible property will entitle its owner(s) to a total payment of approximately:

• Sub-Area A: $21,110 per eligible home.
• Sub-Area B: $16,037 per eligible home.
• Sub-Area C: $7,494 per eligible home.
• Former Owners (sold after July 1, 2024): $444 per eligible home.

These figures are estimates only. The actual amount of any payment will depend on the Court’s award of attorneys’ fees and costs, the Court’s award of service awards, the costs of settlement administration, and the number of Settlement Class Members who submit timely and valid Claim Forms. Final amounts may be more or less than these estimates.

There will be only one payment per single-family home or townhome in the Class Area, regardless of the number of owners. For example, if the home at 123 Maple Street is located in Sub-Area A, is owned jointly by three individuals, and the Court determines that homes in Sub-Area A are entitled to $21,110 per home, then a single payment of $21,110 will be issued for the home at 123 Maple Street, and the three co-owners will be responsible for dividing that payment among themselves. In the case of homes that were sold after July 1, 2024, both the Former Owner and the current owner may be eligible, with the Former Owner’s payment coming from the Former Owners pool described above and the current owner’s payment coming from the applicable sub-area allocation.

Unless you exclude yourself, you will remain a member of the Settlement Class. That means that, in exchange for the consideration provided by the Settlement, you and your heirs, successors, and assigns will release Defendants and their related Released Parties from any and all claims, known or unknown, for property damage or Mitigation Measures that arise out of or relate to the facts alleged in the Second Amended Complaint or Section VII of the Proposed Final Pretrial Conference Order, regardless of whether you submit a Claim Form. A copy of those documents is available for you to review on the on the Court Documents tab. The released claims are described in detail in Section 5 of the Settlement Agreement and in the Release on the Claim Form.

Important: The Settlement does not release, and you will not be giving up, any claims based on alleged personal injury, wrongful death, or claims for medical monitoring.

The Release also includes a waiver of California Civil Code section 1542 (and any similar law of any other state or jurisdiction), which protects against the release of unknown claims. The full text of the section 1542 waiver appears in the Release on the Claim Form and in Section 5 of the Settlement Agreement, which is available on the Court Documents tab.

You are solely responsible for determining the tax consequences of any payment you may receive under this Settlement. Neither the Court, the Defendants, the Plaintiffs/Class Representatives, Class Counsel, nor the Class Administrator is providing any advice or making any representations about the tax consequences of payments made under the Settlement. The Class Administrator will issue the necessary IRS tax forms to Settlement Class Members who receive payments.

To exclude yourself from the Settlement, you must send a written request stating that you want to be excluded from the Settlement Class in Behar v. Northrop Grumman Corporation, et al., Case No. 2:21-cv-03946-HDV-SK. Your request must include your name, address, telephone number, the address of the property you own or owned in the Class Area, and your signature. Your request must be mailed to the Class Administrator, postmarked no later than September 25, 2026, at the following address:

Behar v. Northrop Grumman Class Administrator 
c/o A.B. Data, Ltd. 
EXCLUSIONS
P.O. Box 173001
Milwaukee, WI 53217

You may not exclude yourself by telephone or e-mail. You cannot exclude anyone but yourself. Late-submitted opt-out requests will not be accepted and shall not be effective. If you ask to be excluded, you will not receive any settlement payment, you cannot object to the Settlement, and you will not be bound by anything that happens in this lawsuit. You may then be eligible to sue (or continue to sue) Defendants on your own about the released claims, subject to all applicable defenses.

No. If you exclude yourself, you cannot submit a Claim Form to receive a payment. But, subject to applicable defenses, you may sue, continue to sue, or be part of a different lawsuit against Defendants on your own.

If you are a Settlement Class Member, you may object to the Settlement (in whole or in part) by submitting a written objection to the Court no later than September 25, 2026. To be valid, your written objection must follow the requirements outlined in Question 21 of the Settlement Notice.

If you do nothing, you will receive no payment from this Settlement. Unless you exclude yourself, you will still be bound by the Court’s orders and the Release of Released Claims. You will not be able to start a lawsuit, continue a lawsuit, or be part of any other lawsuit against Defendants about the released claims, ever again.

If multiple people own or owned the property at the same time and each of them files a valid claim, the Settlement Administrator will write a single check payable to all co-owners of the property. Co-owners are responsible for dividing the single payment among themselves; the Settlement Agreement does not provide a procedure for resolving disputes among co-owners.

If you owned a single-family home or townhome in the Class Area on July 1, 2024 but sold it before August 11, 2026, you are a Former Owner. You may submit a Claim Form to receive a share of the $100,000 Former Owners pool described in Question 10 of the Settlement Notice. The current owner of your former home may submit a separate Claim for the applicable sub-area allocation.

The Court has appointed the following attorneys to represent Settlement Class Members (collectively, “Class Counsel”):

• W. Mark Lanier, Alex J. Brown, Ryan D. Ellis, and Michael Akselrud, THE LANIER LAW FIRM, P.C.
• Christopher T. Nidel, Jonathan Nace, and William W. Cowles, NIDEL & NACE, P.L.L.C.
• David P. Page, ENVIRONMENTAL ENERGY & NATURAL RESOURCES ADVOCATES, P.L.L.C.
• Gideon Kracov, LAW OFFICE OF GIDEON KRACOV.

You will not be separately charged for these lawyers. Class Counsel will seek a recovery of attorneys’ fees plus costs and expenses to be paid out of the Settlement Fund. You do not need to hire your own lawyer, however, if you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel intends to apply to the Court for an award of attorneys’ fees of up to forty percent (40%) of the Settlement Fund ($30,000,000.00), as well as reimbursement of reasonable costs and expenses which are estimated not to exceed $3,000,000.00 and costs of settlement administration, which are estimated not to exceed $200,000.00. In the event of an appeal, Class Counsel intends to request additional attorneys’ fees of up to forty-five percent (45%) of the Settlement Fund to compensate for additional work in defending the Settlement on appeal ($33,750,000.00), as well as reimbursement of all reasonable costs and expenses associated with such appeal. Class Counsel will also request Court-approved service awards of up to $30,000 each for Class Representatives Jed Behar and Alisa Behar in recognition of their work and risk in serving as Class Representatives. The Court will determine the actual amounts to be awarded. All such amounts will be paid from the Settlement Fund. Class Counsel’s motion for attorneys’ fees and costs—as well as the motion for Class Representative service awards—will be filed with the Court no later than September 4, 2026, and will be available for review on the Court Documents tab at least 20 days before the deadline to object to the Settlement.

The Court will hold a Final Approval Hearing on November 12, 2026, at 10:00 AM Pacific Time, before the Honorable Hernán D. Vera, at the United States Courthouse, 350 W. 1st Street, Los Angeles, CA 90012, in Courtroom 5B. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court will listen to people who have asked to speak at the hearing. The Court may also decide how much to award to Class Counsel for attorneys’ fees, costs, and expenses, as well as how much of a service award to award to the Class Representatives. We do not know how long the Court’s decision will take. The hearing may be continued or adjourned without further notice.

No. Class Counsel will answer any questions the Court may have. You are welcome to attend at your own expense. If you submit a written objection, you do not need to attend the hearing to have it considered, but you may attend if you wish.

The Settlement Notice summarizes the proposed Settlement. The complete Settlement Agreement, the operative complaint, and other case documents are available for review via the Court Documents tab. You may also review papers filed in the case at the Office of the Clerk of the United States District Court for the Central District of California.

If you have any additional questions or concerns, you may contact the Class Administrator using the contact information available on the Contact Us tab.