Address:
City:
Email address:
BMW Model Year: 20
Vehicle Identification Number:

Model:

(example: 528i)

(The VIN is 17 characters and can be found on the metal plate at the bottom of the driver’s side front windshield or on your sale
or title documents.)
Date of Purchase/Lease:

/

/
CLAIMANT DECLARATION

I declare under penalty of perjury that the information above and the documents I have supplied are true and correct.
Signed On:

/

/

(DD/MM/YYYY)
in

,
(City)

(State)
(Sign your name here)

(Type or print your name here)

(Capacity of person signing ‐ if applicable)
YOU MAY BE ELIGIBLE FOR THE FOLLOWING REIMBURSEMENTS FOR PAST EXPENSES PROVIDED UNDER THE SETTLEMENT:
A. If repairs were performed at an authorized BMW Center, costs (parts and labor) to repair or replace the timing chain module,
oil pump drive chain module, or replace the engine (if damaged due to timing chain or oil pump drive chain failure) will be
reimbursed in accordance with the Reimbursement Chart set forth on the Class Notice at Item 6.
B. If repairs were performed at an independent service center, costs (parts and labor) to repair or replace the timing chain module,
oil pump drive chain module, or replace the engine (if damaged due to timing chain or oil pump drive chain failure) will be
reimbursed in accordance with the Reimbursement Chart set forth on the Class Notice at Item 6 up to $3,000.00 for repairing
or replacing one failed timing chain module and/or oil pump drive chain module.
C.

If repairs were performed at an independent service center, costs (parts and labor) to repair or replace the timing chain module,
oil pump drive chain module, or replace the engine (if damaged due to timing chain or oil pump drive chain failure) will be
reimbursed in accordance with the Reimbursement Chart set forth on the Class Notice at Item 6 up to $7,500.00 for replacing
the engine if damaged due to a failure of the timing chain module and/or oil pump drive chain module.
Page 2 of 2
PLEASE COMPLETE THIS CLAIM FORM ONLY IF YOU ARE
SEEKING ANY OF THE REIMBURSEMENT BENEFITS LISTED ABOVE.
PLEASE SEE QUESTIONS 6 THROUGH 8 ON THE NOTICE FORM, OR SECTION III OF THE SETTLEMENT AGREEMENT, FOR MORE
INFORMATION AND LIMITATIONS.

CLAIMS FOR REIMBURSEMENT FOR PAST EXPENSES
To obtain reimbursement for costs for replacing one (1) failed timing chain module, one (1) failed oil pump drive chain module, or one
(1) failed engine if damaged due to a failure of the timing chain and/or oil pump drive chain modules, you must submit documents
showing:
a.

Whether the repair or replacement was made at an authorized BMW dealer (e.g., a BMW Center), or at a third‐party repair shop;
and

b.

Your Settlement Class Vehicle’s model, model year, and VIN; and

c.

The identity of the owner/lessee of the Settlement Class Vehicle at the time of repair (such as a true copy of a vehicle title,
registration, or license receipt); and

d.

That your Settlement Class Vehicle had fewer than 8 years and 100,000 miles (whichever comes first) at the time of the repair, as
evidenced by a repair order with vehicle mileage from the entity that performed the repair or replacement, or service records
from before and after the repair or replacement; and

e.

The cost of repair, with parts and labor separated; and

f.

Proof of payment for the amount(s) sought for reimbursement (credit‐card receipt, credit‐card statement, or cancelled check);
and

g.

The nature of the repair; and

h.

The part(s) description and part(s) numbers used in the repair; and

i.

The date of repair; and

j.

Evidence of adherence to regular oil changes in accordance with the Class Vehicle’s Condition Based Service Indicator. Documents
evidencing your adherence to the relevant aspects of the vehicle maintenance schedule during the time you owned the vehicle
are required, in particular, scheduled oil changes up to the date/mileage of replacement/repair, within a variance of 1,000 miles
of the scheduled time or mileage maintenance requirements. However, if you cannot obtain maintenance records despite a good
faith effort to obtain them, you may submit a declaration under penalty of perjury detailing what efforts you made to obtain the
records, who you communicated with and when, why the records were not available, and attesting to adherence to the
maintenance schedule and, in particular, scheduled oil changes up to the date/ mileage of the replacement/repair, within the
variance set forth above.

COMPLETED CLAIMS FORMS CAN BE SUBMITTED BY MAIL OR ONLINE.
IF YOU ARE SUBMITTING THIS FORM BY MAIL, COMPLETE THIS CLAIM FORM AND MAIL IT, POSTMARKED ON OR BEFORE THE LATER
OF 30 DAYS AFTER THE DATE OF FINAL APPROVAL OF THE SETTLEMENT OR THE EFFECTIVE DATE OF THE SETTLEMENT, TO BE POSTED
ON THE SETTLEMENT WEBSITE BUT ESTIMATED TO BE MARCH 18, 2021 TO:
Gelis Claims Administrator c/o
Rust Consulting ‐ 7080
PO Box 14
Minneapolis, MN, 55440‐0014
IF YOU ARE SUBMITTING THIS FORM ONLINE, COMPLETE AND SUBMIT THE CLAIM FORM AVAILABLE AT WWW.
TIMINGCHAINMODULESETTLEMENT.COM ON OR BEFORE THE LATER OF 30 DAYS AFTER THE DATE OF FINAL APPROVAL OF THE
SETTLEMENT OR THE EFFECTIVE DATE OF THE SETTLEMENT, TO BE POSTED ON THE SETTLEMENT WEBSITE BUT ESTIMATED TO BE
MARCH 18, 2021.
QUESTIONS? CALL TOLL‐FREE (866) 411‐6985 OR VISIT www.TimingChainModuleSettlement.com

United States District Court for the District of New Jersey
If you are a current or former owner or lessee of a model-year 2012 to 2015 BMW vehicle,
you could get benefits from a class-action settlement.
A federal court has authorized this notice. This is not a solicitation from a lawyer.
•

A nationwide
settlement
has
been reached in
a
class action lawsuit against BMW
of
North America,
LLC, entitled Gelis, et al. v. Bayerische Motoren Werke Aktiengesellschaft and
BMW of North America, LLC, Civil Action No.
2:17-cv07386, involving
the
timing chain and
oil
pump drive chain modules
in
certain
model-year
2012 to
2015 BMW vehicles.

•

The Settlement
expenses

provides
an
and
covered for

•

Your legal rights are affected whether you act or don’t act, so please read this notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SUBMIT A CLAIM FORM

EXCLUDE YOURSELF

OBJECT

GO TO A HEARING

opportunity
to
be
certain future repairs.

Make a
claim to
receive reimbursement for
eligible past
expenses
potentially
available
to
you
under the
Settlement.

reimbursed

for

Claims must be
by
the
thirty (30)
the
date
Approval
Settlement

certain past

submitted
later of
days after
of
Final
of
the
or
the

Effective
Date of
the
Settlement,
to
be
posted on
the
Settlement
Website
but
estimated
to
be
March 18, 2021.
See Question 8, below.
Requests
for
Exclusion
must be
postmarked
by
January 19, 2021.
See Question 12,
below.

Write to
Settlement
Class
Counsel
and
Defendant’s
Counsel
to
exclude yourself
from (“opt out”
of)
the
Settlement.
This is
the
only
option that
allows you
to
be
part
of
any
other lawsuit, or
your own
lawsuit,
against BMW of
North
America
about the
legal claims released
in
this
Settlement.
Write to
the
judge about Objections
must be
why
you
do
not
postmarked
by
like
the
Settlement.
January 19, 2021.
See Question 17, below.
Ask
to
speak in
court The
Final Approval
to
the
judge about
Hearing is
currently
the
Settlement.
scheduled
for

QUESTIONS? CALL TOLL-FREE (866) 411-6985 OR VISIT www.TimingChainModuleSettlement.com
1
-

February 16, 2021.
See Questions 19 to 21, below.
DO NOTHING

•

These
in

•

The Court in
Settlement
settlement

See Question 22, below.
up
the
benefits to
which you
may
be
entitled under the
Settlement
and
your
right to
be
part
of
any
other
lawsuit against BMW of
North
America
about the
legal
claims released
by
the
Settlement
(but
not
your right to
future repairs under the
prospective
repair
program,
explained
below).
options -and the deadlines to exercise them
-are
explained
Give

rights and
this
notice.

charge of
this
case
still
must decide whether to
approve the
before any benefits can be distributed.
Please be
patient and
check the
website for
updates.
WHAT THIS NOTICE CONTAINS

BASIC INFORMATION
1.
2.
3.
4.

Why
What
Why
Why

have
is
is
is

I
the
this
there

PAGE 3
received
this
notice?
lawsuit about?
a
class action?
a
Settlement?

WHO IS IN THE SETTLEMENT
5. How
are

do
I
included

know
in

PAGE 3-4
if
the

I
am
Settlement?

part

of

the

Settlement?

THE BENEFITS: WHAT YOU GET
6. What
7. What

are
am

the
I

do
if
will

I
my
I

benefits of
giving up

the
in

Settlement?
exchange

for

the

Settlement

I
I
I
do

get
claim
get

the
for
the

benefits of
benefits is
benefits?

the
Settlement?
denied?

exclude myself from
exclude myself, can
don’t exclude myself,
I
exclude myself

this
I
can
from

PAGE 6

Settlement?
get
anything
I
sue
later?
the
Settlement?

THE LAWYERS REPRESENTING YOU
15. Do

I

have

benefits?
PAGE 6

EXCLUDING YOURSELF FROM THE SETTLEMENT
11. Can
12. If
13. If
14. How

vehicles

PAGE 4-5

HOW TO GET BENEFITS
8. How
9. What
10. When

What

a

lawyer in

from

this

Settlement?

PAGE 7
the

case?

QUESTIONS? CALL TOLL-FREE (866) 411-6985 OR VISIT www.TimingChainModuleSettlement.com
2
-

16. How

will

the

lawyers be

paid?

OBJECTING TO THE SETTLEMENT