NOTICE OF CLASS ACTION

The Circuit Court of Montgomery County, Maryland has authorized this class action Notice. You are not being sued.

The Circuit Court of Montgomery County, Maryland certified a class action lawsuit against Just4 Veterans, LLC and Frederick Castanos Justo who provide services to U.S. military veterans nationally, relating to the veterans’ claims for disability benefits from the U.S. Department of Veterans Affairs (the “VA”). This notice explains your rights and how the class action lawsuit might affect you.

This notice explains your rights and how the class action lawsuit might affect you.

• Grant Gallagher (“Mr. Gallagher”), is a resident of Texas and a honorably discharged veteran of the Air Force. Emily Heibel (“Ms. Heibel”), is a resident of Florida and a honorably discharged veteran of the United States Marine Corps. Mr. Gallagher and Ms. Heibel filed this lawsuit against Just4 Veterans, LLC and Frederick Castanos Justo. Mr. Gallagher and Ms. Heibel are called the Plaintiffs, and Just4Veterans, LLC and Frederick Castanos Justo, the Defendants.

• Plaintiffs allege that Defendants assist veterans with applying for VA disability benefits despite lacking accreditation they allegedly needed to do so and that Defendants charge veterans illegally excessive fees. Plaintiffs allege that Defendants violated the Maryland Consumer Protection Act, breached their fiduciary duties, and converted funds that belong to Plaintiffs. On behalf of the Class, Plaintiffs seek a declaratory judgment that any contracts between Plaintiffs/class members and Just4 Veterans are void or voidable and that all amounts received by Defendants, plus interest and investment returns, be returned to Plaintiffs and Class members; an order that Defendants have illegally charged Plaintiffs and the Class members fees related to Plaintiffs’ and Class members’ VA disability benefits; disgorgement of all funds received by Defendants under the contracts; imposition of a constructive trust on Defendants’ net assets and revenues; equitable relief preventing any further solicitation or contracts between Defendants and veterans who are or could be in the class; an award of punitive damages, attorneys’ fees, costs, and pre and post judgment interest; other equitable relief to which Plaintiffs and Class members may be shown to be entitled; and any such other relief as the Court deems just, equitable, and proper.

• Defendants contend that they provide a valuable and completely legal service. Defendants assert that their provision of educational services helps fellow veterans obtain the maximum possible disability benefits from the VA to which they are entitled.

• If you received a postcard or email notice of this class action, you have been identified as a class member because the Defendants’ records indicate that you are a class member because you are a veteran who has been charged a fee by Just4Veterans in connection with your VA disability claim(s).

• On February 13, 2025, Judge J. Bradford McCullough of the Montgomery County Circuit Court of Maryland, certified this case as a class action. A class action is a lawsuit where the claims of a group of people are all decided at the same time by a single court.

• Judge J. Bradford McCullough appointed lawyers to represent the Class. The Class Counsel in this lawsuit is called The Pels Law Firm. The lawyers have not been paid for their work, and they have paid for all the expenses of this lawsuit out of pocket. If they win the trial or a settlement is reached, they will ask the Court to require Defendants to pay attorneys’ fees and expenses.

• The Court has not ruled in favor of the Plaintiffs or the Defendants.

• There is no money available now, and no guarantee that there will be. However, your legal rights are affected, and you have a choice to make now.

View the full Class Action Notice

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

Do Nothing Stay in the lawsuit, await the outcome, and give up certain rights. By doing nothing, you keep
the possibility of receiving money or benefits that may be awarded if Plaintiffs win a trial or
reaches a class wide settlement. But, you also give up any rights to sue Defendants separately
for the same legal claims in this lawsuit. If the Plaintiffs lose, your claims would also likely
be lost.
Exclude Yourself Opt-out of the lawsuit. This means that you choose not to be part of the lawsuit. If you ask
to be excluded and money or benefits are later awarded, you will not receive those benefits.
But, you will keep the right to sue Defendants separately about the same legal claims in this
lawsuit. To exclude yourself, you must postmark a written request for exclusion on or before
45 Days from the date on the Postcard Notice. This is discussed below in more detail in
Item 12.

TABLE OF CONTENTS

Basic Information
1. Why did I get this notice?

If you are viewing this Notice on the Class Website after receiving a notice by mail, or an email notice, Defendants records indicate that you are a member of the Class in this case.

The Class is defined as follows:

All veterans who have been charged a fee by Just4Veterans, LLC in connection with their U.S. Department of Veterans Affairs disability claim(s).

If you are not sure if you are a class member, you can contact the lawyers that the Court appointed to represent you.

The Judge in charge of this case is the Honorable J. Bradford McCullough of the Montgomery County Circuit Court of Maryland. The case is known as Grant Gallagher, et. al v. Just4Veterans LLC, et al, Case No. C-15-CV-23-003578.

2. What is the lawsuit about?

Just4Veterans, LLC is a Maryland limited liability company that provides services to U.S. military veterans nationally, relating to the veterans’ claims for disability benefits from the U.S. Department of Veterans Affairs (the “VA”). Mr. Justo is the founder, owner, and Chief Executive Officer of Just4Veterans.

Plaintiffs allege that Defendants assist veterans with applying for VA disability benefits despite lacking accreditation they allegedly needed to do so and that Defendants charge veterans illegally excessive fees. Plaintiffs allege that Defendants violated the Maryland Consumer Protection Act, breached their fiduciary duties, and unlawfully converted funds that rightfully belong to Plaintiffs. On behalf of the Class, Plaintiffs seek a declaratory judgment that any contracts between Plaintiffs/class members and Just4Veterans are void or voidable and that all amounts received by Defendants, plus interest and investment returns, be returned to Plaintiffs and Class members; an order that Defendants have illegally charged Plaintiffs and the Class members fees related to Plaintiffs’ and Class members’ VA disability benefits; disgorgement of all funds received by Defendants under the contracts; imposition of a constructive trust on Defendants’ net assets and revenues; equitable relief preventing any further solicitation or contracts between Defendants and veterans who are or could be in the class; an award of punitive damages, attorneys’ fees, costs, and pre and post judgment interest; other equitable relief to which Plaintiffs and Class members may be shown to be entitled; and any such other relief as the Court deems just, equitable, and proper.

Defendants deny that they violated any law. Defendants contend that they provide a valuable and completely legal service. Defendants assert that their provision of educational services helps fellow veterans obtain the maximum possible disability benefits from the VA to which they are entitled. The Court has not ruled in favor of the Plaintiffs or the Defendants.

The Court has not ruled in favor of either side at this time. The only thing the Court has decided is that the case can proceed as a class action.

3. What is a class action?

Class actions are lawsuits in which the claims and rights of many people are decided in a single proceeding. In a class action, individual plaintiffs bring their lawsuit on behalf of all members of a larger group. The larger group is called “the class.” In a class action, people with similar claims are treated alike. The court is guardian of the class’s interests and supervises the prosecution of the class claims by counsel for the class to assure that the representation is adequate. Class members are not individually responsible for the costs or fees of counsel, which are subject to court award in the event the class action is successful.

4. Why is this case a class action?

The Court decided that this lawsuit can be a class action because it meets the requirements of the Maryland Rule 2-231 which governs class actions in circuit courts of Maryland.

Specifically, the Court found that:

  • The class is so numerous that joinder of all members is impracticable;
  • There are legal questions and facts that are common to all class members;
  • Named Plaintiff Grant Gallagher’s and Named Plaintiff Emily Heibel’s claims are typical of the claims of the rest of the Class;
  • The Named Plaintiffs and the lawyers representing the Class will fairly and adequately represent the Class’s interests;
  • The final declaratory and injunctive relief sought is appropriate to the class as a whole;
  • The common legal questions and facts are more important than questions that affect only individuals; and
  • A class action is superior to other available methods for the fair and efficient adjudication of the controversy.

More information about why the Court is allowing this lawsuit to be a class action is in the Court’s Class Certification Opinion And Order, which is available at the Class Website (link to the Class Certification Opinion and Order).

The Claims in the Lawsuit
5. What are the Plaintiffs’ claims?

In the lawsuit, Plaintiffs allege that Defendants assist veterans with applying for VA disability benefits despite lacking accreditation they allegedly needed to do so and that Defendants charge veterans illegally excessive fees. Plaintiffs allege that Defendants violated the Maryland Consumer Protection Act, breached their fiduciary duties, and unlawfully converted funds that rightfully belong to Plaintiffs.

You can read the Plaintiff’s First Amendment to Plaintiffs’ Class Action Complaint at the Class Website. (link to Plaintiff’s First Amendment to Plaintiff’s Class Action Complaint)

6. How do Defendants respond?

Defendants deny that they did anything wrong. Defendants deny that they violated any law. Defendants contend that they provide a valuable and completely legal service. You can read Defendants’ Answers at the Class Website (link to Defendant’s Answers).

7. Has the Court decided who is right?

The Court has not decided whether Defendants or Plaintiffs are correct. By establishing the Class and authorizing this Notice, the Court is not suggesting that the Plaintiffs will win or lose the case. The Plaintiffs must still prove their claims at a trial.The Court has not decided whether Defendants or Plaintiffs are correct. By establishing the Class and authorizing this Notice, the Court is not suggesting that the Plaintiffs will win or lose the case. The Plaintiffs must still prove their claims at a trial.

8. What are the Plaintiffs asking for?

Plaintiff seeks (1) an order that Defendants have illegally charged Plaintiffs and the Class members fees related to Plaintiffs’ and the Class members’ VA disability benefits; (2) disgorgement of all sums received from Plaintiffs and the Class members by Defendants; (3) imposition of a constructive trust on Defendants’ net assets and revenues; (4) an order enjoining Defendants from continuing their practices; (5) an award of attorney’s fees; (6) declarations consistent with the above requests including, but not limited to, a declaration that any contracts entered into by Defendants with Plaintiffs and Class members are void/rescinded and that all amounts received by Defendants, plus interest and investment returns, be returned to Plaintiffs and Class members; (7) award of damages in an amount in excess of $25,000; (8) an award to Plaintiffs and the Class members for attorney’s fees, punitive damages, costs, disbursements and pre and post judgment interest; (9) other equitable relief to which Plaintiffs and the Class members may be shown to be entitled; and (10) any such other relief as the Court deems just, equitable, and proper.

9. Is there any money available now?

No money or benefits are available now because the Court has not yet decided whether Defendants did anything wrong, and the two sides have not settled the case. There is no guarantee that money or benefits ever will be obtained. If they are, you will be notified about how to be eligible for a share.

Your Rights and Options

As a class member, you have to decide whether to stay in the Class or ask to be excluded before trial, and you have to decide this now.

10. What happens if I do nothing at all?

You do not have to do anything now if you want to keep the possibility of getting money or benefits from this lawsuit. By doing nothing, you are staying in the Class. If you stay in and Plaintiffs obtain money or benefits, either as a result of a trial or a settlement, you will be notified about how to be eligible for a share, or how to ask to be excluded from any settlement. Keep in mind that if you do nothing now, regardless of whether Plaintiffs win or lose at trial, you will not be able to sue, or continue to sue, Defendants—as part of any other lawsuit—for the same legal claims that are the subject of this lawsuit. This means that if you do nothing, you are not able to individually sue Just4Veterans, LLC and Frederick Castanos Justo relating to any services they provided relating to your claim(s) for disability benefits from the U.S. Department of Veterans Affairs. You will be legally bound by all orders the Court issues and judgments the Court makes in this class action.

11. Why would I ask to be excluded?

If you already have your own lawsuit against Defendants and want to continue it, you need to ask to be excluded from the Class. If you exclude yourself from the Class—which means to remove yourself from the Class, and is sometimes called “opting out” of the Class—you will not get any money or benefits from this lawsuit even if the Plaintiffs obtain them as a result of a trial or from any settlement (that may or may not be reached). However, you may then be able to sue or continue to sue Defendants for these claims at any time. If you exclude yourself, you will not be legally bound by the Court’s judgments in this class action.

If you start your own lawsuit against Defendants after you exclude yourself, you will have to either represent yourself or hire your own lawyer for that lawsuit, and you will have to prove your claims. If you do exclude yourself so you can start or continue your own lawsuit against Defendants, you should talk to a lawyer soon, because your claims may be subject to a statute of limitations.

12. How do I ask to exclude myself?

To ask to be excluded, you must send a written request either by mail, or by email, to the Notice Administrator on or before 45 Days from the date on the Postcard Notice. Your request must include your name and address, and state that you request to be excluded from the Gallagher v. Just4Veterans class action.

The Administrator’s mailing address is: The Pels Law Firm, 4845 Rugby Ave, Third Floor, Bethesda, MD 20814.

The email address is: mhiggins@pelslaw.com

The Lawyers Representing You
13. Do I have a lawyer in this case?

The Court has appointed The Pels Law Firm as Counsel for the Class. The Court has determined that The Pels Law Firm and its attorneys are qualified to represent you and all class members. More information about the law firm is available at www.pelslaw.com. You can contact the lawyers via phone at 301-986-5570 and/or via email to jpels@pelslaw.com and jzelaya@pelslaw.com.

14. How will the lawyers be paid?

If Class Counsel obtains money or benefits for the Class, they will ask the Court to require Defendants to pay their fees and expenses. You will not have to pay these fees and expenses individually. If the Court grants Class Counsel’s request, the fees and expenses would be either deducted from any money obtained for the Class or paid separately by Defendants.

15. Should I get my own lawyer?

You do not need to hire your own lawyer because Class Counsel is working on your behalf. But, if you want a lawyer to represent you individually, you will have to hire that lawyer.

Getting More Information
16. Are there more details available?

This Notice is only a summary. To review documents filed in the case for more detail, visit the Class Website. You may also contact the Class Counsel via phone at 301-986-5570 and/or via email to jpels@pelslaw.com and jzelaya@pelslaw.com.

Contact us today if you have any questions about this class action

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