GLORIA TURNAGE v. AION MANAGEMENT LLC, et al.

You received this Notice because you signed a lease at an apartment complex in Virginia managed by AION Management LLC between October 10, 2023, and November 1, 2025. Records from AION indicate you are a class member.

This Notice informs you about the proposed settlement and your rights. Before any final judgment is entered, the Court will have a hearing to decide whether to approve the proposed settlement. The proposed settlement will be finally approved only after any objections or appeals are resolved. If the proposed settlement is finally approved, then you will benefit from the relief provided by the proposed settlement. Once the proposed settlement is final, you will also be bound by the release and other provisions of the proposed settlement.

This notice is only a summary of the proposed settlement. More details about the proposed settlement, the date when appeals are no longer allowed and the settlement is final, deadlines for certain actions, and your options are available in a longer document called the Settlement Agreement. You can get a copy of the Settlement Agreement by visiting the Important Court Documents page on this website.

The class action lawsuit is known as Gloria Turnage v. AION Management LLC, et al., No. 3:25cv0840, and is pending in the United States District Court for the Eastern District of Virginia, with Judge Robert E. Payne presiding. The individual who sued is called the Plaintiff; the entities that they sued are called the Defendants. The Plaintiff is Gloria Turnage. The Defendants are AION Management LLC and AP 11 North LLC.

The lawsuit alleges that Defendants violated the VCPA and VRLTA by making misrepresentations in connection with certain fees and assessing fees that they could not assess under Virginia law. Defendants deny the Plaintiff’s allegations and theories of relief and deny that they are liable to the Plaintiff or any of the putative settlement class members. The Court has not decided whether either side is right or wrong. Instead, both sides agreed to settle the case and provide benefits to the class.

The Plaintiff filed this case as a proposed class action. When the parties reached this proposed settlement, the Court had not decided whether the case could be a class action. As part of the proposed settlement, the Court certified a tentative class action for settlement purposes only, under Federal Rule of Civil Procedure 23(b)(3). If the proposed settlement is not finally approved, then the Court will later determine if the case may or may not proceed as a class action.

The Court has decided that everyone who fits the following description is a “Settlement Class Member”:

All consumers: (1) who executed a lease at any of the AION-Managed Properties and (2) paid or were obligated to pay any Disputed Fee from October 10, 2023 through November 1, 2025.

Because you have received this Notice, you have been identified as a Settlement Class Member.

The proposed settlement provides a monetary payment to all Settlement Class Members from a fund totaling $776,628. This is approximately, $141 per Class Member.

Pursuant to the Court’s approval, the Defendants will separately pay a Service Award of up to $7,500 for the Plaintiff, attorneys’ fees and costs to Class Counsel in an amount up to $388,314, and Administrative Costs of the Settlement Administrator in an amount of $25,000.

As part of the Settlement, Defendants have also agreed to remove the Disputed Fees from leases and lease renewals going forward for a period of five years from the Effective Date of the Settlement.

You will not have to pay or buy anything to benefit from the relief provided by the Settlement.

In general terms, if the proposed settlement is finally approved by the Court, then you will be giving up the right to file a lawsuit against AION Management LLC and its affiliates, including your landlord, for claims under the VCPA or VRLTA related to any of the Disputed Fees that arose between October 10, 2023, and November 1, 2025.

The precise terms of the dismissal and release are explained in the Settlement Agreement, which you can view on the Important Court Documents page of this website. The Court’s order will apply to you even if you object to the settlement or have any other claim, lawsuit, or proceeding pending against any of the Defendants for violations of the VCPA or VRLTA related to the Disputed Fees.  If you have any questions about the release, please read through the Important Court Documents on this site for additional information or consult with a lawyer. See FAQ 7 below for more information regarding your options in seeking legal advice concerning the settlement.

Yes. You have the opportunity to opt out of the Settlement by submitting a written Request for Exclusion to Turnage v AION, c/o Settlement Administrator, PO Box 23668, Jacksonville, FL 32241, postmarked no later than September 8, 2026. To be valid, a Request for Exclusion must be personally signed and must include: (i) your name, address and telephone number; and (ii) a statement substantially to the effect that: “I do not want to be part of the Settlement Class in Turnage v. AION.” Notwithstanding the foregoing, no person within the Settlement Class may submit a Request for Exclusion for any other person in the Settlement Class.

If you timely submit a valid Request for Exclusion, you will exclude yourself from the Settlement Class and will not be bound by further orders or judgments in the Litigation, subject to Court approval. You will preserve your ability to independently pursue, at your own expense, claims that you claim to have against the Defendants or other Released Parties. No person who has opted out of the settlement may object to any part of the Settlement Agreement.

Yes. The Court approved the following individuals to represent you and other Settlement Class Members: Kristi Kelly, Andrew Guzzo, Casey Nash, Pat McNichol and Matt Rosendahl of Kelly Guzzo, PLC at 3925 Chain Bridge Road, Suite 202, Fairfax, Virginia 22030. Telephone: (703) 424-7572, Email: [email protected].

The Court has appointed these lawyers as Class Counsel. You will not be charged for these lawyers.

The attorneys representing the class have handled this case on a contingency basis. To date, they have not been paid anything for their work. Class Counsel will request that the Court award attorneys’ fees and expenses for the time and effort they have spent on this case. The amount that will be requested by Class Counsel will be $388,314 and a service award for the Named Plaintiff of up to $7,500.

Any approved attorneys’ fees and expenses and the Plaintiff’s service award will be paid separately by the Defendants and no Settlement Class Member will owe or pay anything directly for the attorneys’ fees and expenses of Class Counsel. It will also not reduce the payment you will receive as part of the Settlement.

If you are a Class Member, then you can object to the proposed settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views.

To object to this Settlement Agreement, you must file your objection in writing with the Clerk of Court no later than September 8, 2026. You must also serve a copy of your objection to counsel for both Plaintiff and Defendants. The objection must include certain information outlined in the Court’s Preliminary Approval Order and the Settlement Agreement which can be found on the Important Court Documents page of this website. If you fail to timely file and serve a written objection, you shall not be permitted to object to the approval of the settlement or Settlement Agreement and shall be foreclosed from seeking any review of the settlement or the terms of the Settlement Agreement by appeal or other means.

You will not be permitted to object to the settlement or the Settlement Agreement if you decide to exclude yourself from the settlement.

The Court will hold a final approval hearing on October 21, 2026, at 10:00 a.m. before the Hon. Robert E. Payne, in the United States District Court for the Eastern District of Virginia in Richmond, Virginia.

At this hearing, the Court will consider whether the proposed settlement is fair, reasonable, and adequate. The Court will consider all timely and proper objections. You do not have to attend the hearing. The Court may also decide how much to award Class Counsel and the Plaintiff. After the hearing, the Court will decide whether to finally approve the proposed settlement.

The Court may change the date of the final approval hearing without further notice to the Class. You should check the Case Home and Key Dates pages of this website after October 21, 2026, to confirm the hearing date, the court-approval process, and the Effective Date.

A copy of your marriage license, divorce decree, or court order is required for a name change. Please also include a copy of your Driver's License or State ID. 

You can submit the documentation via email at [email protected]. In your email, put "Name Change" in the subject line. In the body of the email, provide the Notice ID, original name, and address of the Class Member on the Notice you received. Also provide the new name, address, and phone number that you would like for future correspondence.

Alternatively, you can submit the required documents by mail to: Turnage v Aion Management, c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

Please notify the Settlement Administrator of any changes in your mailing address so that future correspondence will be sent to the correct address.

To update your mailing address with your Notice ID and PIN, you can use the Update Address page on this website. Alternatively, contact the Settlement Administrator via email at [email protected]. Please put "Change of Address" in the subject line and provide your full name, previous address, current address, and the Notice ID from your notice in the body of the email. A third alternative is to mail that information to: Turnage v Aion Management, c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

Payment may be issued to the beneficiary of a deceased Class Member by requesting a name change for the payee.

Two documents are required for a name change for a deceased Class Member. They are: 1) A Copy of the death certificate, and 2) Documentation providing evidence to show the new payee as legal beneficiary – this could be a will, estate documentation, etc. The documentation will be reviewed when received. We may reach out to you with additional questions, if necessary.

You can submit these documents via email at [email protected], put ‘Name Change’ in the subject line. In the body of the email, provide the Notice ID, original name and address of the Class Member on the Notice you received. Also provide the new name, address and phone number that you would like on future correspondence.

Alternatively, you can submit the required documents by mail to: Turnage v Aion Management, c/o Settlement Administrator, PO Box 23678, Jacksonville, FL 32241.

More details about the proposed Settlement can be read in the Court documents found on the Important Court Documents page of this website.

You can contact Class Counsel at [email protected].

You may also email [email protected]. Please include your Notice ID and PIN.