Frequently Asked Questions

A Court authorized this Notice because you have a right to know about the proposed settlement of the Lawsuit and all of your options before the Court decides whether to approve the proposed settlement. This Notice explains the Lawsuit, the settlement, your legal rights, what benefits are available, and who can get them.

Judge Marcella O. McLaughlin of the Superior Court of California, County of San Diego is currently overseeing this case and will decide whether to approve the settlement. The case is titled Hugo Maldonado v. Hilton Grand Vacations Inc., et al., case number 25CU029217C. The individual who is suing is called the “Plaintiff.” The companies they are suing are Hilton Grand Vacations Inc., Hilton Resorts Corporation, and Grand Pacific Marbrisa Owners Associations, Inc., which are called the “Defendants.”

In a class action, one or more people called “Class Representative” or “Plaintiff” (in this case, Hugo Maldonado) sue on behalf of people who have similar claims. All these people are a “Class” and each is a “Class Member.” One court resolves the issues for all Class Members, except for those who opt out of the Class.

Plaintiff brought claims against Defendants regarding fees charged by Defendants to hotel guests. Plaintiff contends that Defendants charged fees, including parking fees, that were not included in the advertised price of hotel rooms at MarBrisa Carlsbad.

Defendants maintain that they did nothing wrong. The proposed settlement to resolve this Lawsuit is not an admission of guilt or any wrongdoing of any kind by Defendants.

The Court has not decided in favor of the Class or Defendants. Instead, the Class Representative and Defendants agreed to a settlement. This way, they avoid the cost, burden, and uncertainty of a trial and the consumers allegedly affected can get benefits. The Class Representative and his attorneys think the proposed settlement is best for all Class Members.

The Court has decided that everyone who fits the following description is a Class Member, and is thus included in the settlement:

All persons who purchased a hotel room at MarBrisa through the website www.marbrisacarlsbad.com within the time period spanning June 3, 2021 to June 17, 2025 and were charged any fee(s) that were allegedly not displayed in the advertised price at the time of purchase, including but not limited to Parking Fees (the “Class”).

If you are still not sure whether you are included in the Class, you can call toll-free [Toll-free number to be confirmed], or write to Maldonado v. Hilton Grand Vacations Settlement Administrator
c/o Apex Class Action LLC
[Mailing address to be confirmed], for more information. See the Contact page.

The Parties to the Lawsuit have agreed to a $750,000 settlement (the “Gross Settlement Amount”). Defendants will deposit the Gross Settlement Amount into an account controlled by the Settlement Administrator, a neutral company that the Court has appointed to send this notice, calculate and make payments, process Class Members’ opt-out requests, and perform other tasks necessary to administer the settlement.

After deducting any Court-approved attorneys’ fees and costs, incentive awards to the Class Representative, and administrative and notice costs, the Settlement Administrator will determine the Class Payment that will be made available to Class Members in accordance with the description provided in the response to Question 8 below.

It is possible the Court will decline to grant final approval of the settlement or decline to enter a judgment. It is also possible the Court will enter a judgment that is reversed on appeal. Plaintiff and Defendants have agreed that, should either of these events occur, the settlement will be void: Defendants will not pay any money and Class Members will not release any claims against Defendants.

Each Class Member that elects to receive a Class Payment will receive a pro rata distribution of the settlement. The amount of the Class Payment will depend on the total number of Class Members who choose to receive a Class Payment and on the amount of Court-approved deductions from the Gross Settlement Amount.

Plaintiff and/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement Amount, the amounts of which will be decided by the Court at the final approval hearing:

• Up to $262,500 (35% of the Gross Settlement Amount) to Class Counsel for attorneys’ fees and up to $40,000 for their litigation expenses. To date, Class Counsel have worked and incurred expenses on this case without payment.
• Up to $7,500 to the Class Representative as an incentive award for filing the Lawsuit, working with Class Counsel and representing the Class. An incentive award will be the only money the Class Representative will receive other than the Class Representative’s Class Payment, should he elect to receive a Class Payment.
• An estimated $25,750 to the Settlement Administrator for services administering the settlement.

Class Members have the right to object to any of these deductions. The Court will consider all objections.

If you received a notice indicating that Defendants have determined that you may be a Class Member and do not opt out of the Class, you have the option of electing to receive a Class Payment by either electronic payment (via PayPal, Venmo, or Zelle), ACH transfer, or physical check. To receive a Class Payment, you must inform the Settlement Administrator by January 21, 2027 and let the Settlement Administrator know whether you elect to receive the payment by electronic payment (via PayPal, Venmo, or Zelle), ACH transfer, or physical check and the corresponding mailing address or banking information for the payment’s distribution. You can choose to receive a Class Payment on the Payment Election page. After the Court issues its final approval of the settlement, the Settlement Administrator will then send you payment using the method you have chosen.

If you elect to receive a Class Payment by check, your check will show the date when the check expires (the “void date”). If you don’t cash your Class Payment by the void date, your check will be automatically cancelled, and the monies will be irrevocably lost to you because they will be paid to a non-profit organization or foundation authorized by the Court.

If you choose to receive a check and change your address, be sure to notify the Settlement Administrator as soon as possible. Question 26 has the Settlement Administrator’s contact information.

The Court will hold a hearing on February 19, 2027 to decide whether to grant final approval of the settlement. Class Payments will be distributed to Class Members after the Court grants final approval of the settlement and any objections are overruled with finality. The Court may also elect to move the final approval hearing to a different date or time in its sole discretion, without providing further notice to the Class. The date and time of the final approval hearing can be confirmed on this website.

If you lose or misplace your settlement check before cashing it, contact the Settlement Administrator, who will replace it as long as you request a replacement before the void date on the face of the original check. If you do not request a replacement check before the void date, you will have no way to recover the Class Payment.

Unless you opt out, you will remain in the Class. If the settlement is approved and becomes final, all of the Court’s orders will apply to you and legally bind you. You won’t be able to sue, continue to sue, or be part of any other lawsuit against Defendants that is related to the subject matter of the claims in this Lawsuit. The rights you are giving up are called Released Claims, which are explained in Question 13.

Each member of the Class who has not timely requested to opt out from the Class, and each of their respective successors, assigns, legatees, heirs, and personal representatives, will be deemed to have released Defendants and its past, present, and future successors and predecessors in interest, subsidiaries, affiliates, direct or indirect parents, wholly or majority-owned subsidiaries, divisions, affiliated and related entities, including Grand Pacific Resort Services, LP and Grand Pacific Resorts, Inc., partners and privities, and each of Defendants’ past, present, and future officers, directors, shareholders, employees, agents, principals, heirs, representatives, accountants, auditors, consultants, attorneys, insurers, and reinsurers of all manner of action, causes of action, claims, demands, rights, suits, obligations, debts, contracts, agreements, promises, liabilities, damages, charges, penalties, losses, costs, expenses, and attorneys’ fees, which they have or may have that are based on, or arise from, one or more of the same factual predicates asserted in the Complaint, including all claims arising out of Defendants alleged failure to disclose fees associated with their sale of hotel rooms, that occurred prior to the Settlement Date.

If you want to keep the right to sue or continue to sue Defendants at your expense for any claim related to the subject matter of this Lawsuit, and you do not want to receive a Class Payment from this settlement, you must take steps to get out of the settlement. This is called opting out of, or excluding yourself from, the settlement.

To opt out, you must send a letter with the following information:

• Your full name, address, telephone number, and email address;
• A statement that you wish to opt out of the Class in Hugo Maldonado v. Hilton Grand Vacations Inc., et al., case number 25CU029217C; and
• Your signature

You can download a form to use for your opt-out request on the Settlement Documents page.

You must mail your signed opt-out request to:
Maldonado v. Hilton Grand Vacations Settlement Administrator
c/o Apex Class Action LLC
[Mailing address to be confirmed]

Your opt-out request must be postmarked no later than December 22, 2026 or it will be invalid. You must make the request yourself. If someone else makes the request for you, it will not be valid.

No. If you opt out, you are telling the Court that you don’t want to be part of the Class in this settlement. You can only get a Class Payment if you remain in the Class. See Question 9 for more information.

No. Unless you opt out, you are giving up the right to sue Defendants regarding any claims that are related to the subject matter of the claims in this Lawsuit. You must opt out of this Lawsuit to have the ability to start or continue with your own lawsuit or be part of any other lawsuit against Defendants related to the subject matter of the claims in this Lawsuit.

Yes. The Court appointed the following attorneys to represent you as Class Counsel:

Jack Day
Calvin Bryne
Day Bryne & McIntosh
129 West Wilson Street, Suite 105
Costa Mesa, CA 92627
jack@dbm.law
calvin@dbm.law

Paul Haines
Haines Law Group, APC
2155 Campus Drive, Suite 180
El Segundo, CA 90245
phaines@haineslawgroup.com

You do not have to pay Class Counsel out of your own pocket. If you want to be represented by your own lawyer and have that lawyer appear in Court for you in this case, you may hire one at your own expense.

Class Counsel will ask the Court for an award of attorneys’ fees of up to $262,500 (35% of the Gross Settlement Amount) and up to $40,000 for their litigation expenses, as well as incentive awards of up to $7,500 to the Class Representative. Class Counsel will move for both the incentive awards and for attorneys’ fees and costs, and the Court will determine the amounts to be awarded. All of these amounts, as well as the administrative and notice costs associated with the settlement, will be paid from the $750,000 that the Parties settled for before making Class Payments to Class Members. A copy of Class Counsel’s motion for attorneys’ fees and costs and for the Class Representative’s incentive awards will be available on the Settlement Documents page.

If you are in the Class, you are not required to hire your own lawyer because Class Counsel is representing you. However, if you want your own lawyer, you may hire one at your own expense. If you opt out of the settlement, you will no longer be represented by Class Counsel once the settlement is approved.

If you are a Class Member, you can tell the Court if there is something about the settlement that you do not like by submitting an objection. You can’t ask the Court to order a different settlement; the Court can only approve or reject the proposed settlement. If the Court denies approval, no Class Payments will be sent out and the Lawsuit will continue.

You may object to the settlement in writing by sending written notice to the Settlement Administrator. All written objections and supporting papers must (a) clearly identify the case name and number (Hugo Maldonado v. Hilton Grand Vacations Inc., et al., case number 25CU029217C); (b) include your full name, address, telephone number, and email address of your attorney (if you are represented by counsel); (c) state the grounds for the objection; (d) be mailed to the Settlement Administrator at Maldonado v. Hilton Grand Vacations Settlement Administrator
c/o Apex Class Action LLC
[Mailing address to be confirmed]; and (e) be postmarked on or before December 22, 2026.

You may also appear and request to make an objection at the final approval hearing before the Court on February 19, 2027, either in person or through your lawyer, if you choose to retain your own lawyer. The Court may elect to move the final approval hearing to a different date or time in its sole discretion, without providing further notice to the Class. The date and time of the final approval hearing can be confirmed on this website.

Before deciding whether to object, you may wish to see what Plaintiff and Defendants are asking the Court to approve. Class Counsel and/or Plaintiff will file in Court a Motion for Final Approval that includes, among other things, the reasons why they think the proposed settlement is fair, and a motion stating (i) the amount Class Counsel is requesting for attorneys’ fees and litigation expenses and (ii) the amount the Class Representative is requesting as an incentive award. Upon reasonable request, Class Counsel will send you copies of these documents at no cost to you. You can also view these documents on the Settlement Documents page.

Objecting is simply telling the Court that you don’t like something about the settlement. You can object only if you stay in the Class (and do not opt out). Opting out is telling the Court that you don’t want to be part of the Class. If you opt out, you cannot object because the settlement no longer affects you.

The Court will hold the final approval hearing on February 19, 2027, at 9:30 a.m. Pacific, at the Hall of Justice Courthouse, Department 72, located at 330 W. Broadway, San Diego, CA 92101. At this hearing, the Court will decide whether to approve the settlement, Class Counsel’s request for attorneys’ fees and costs, and any incentive awards to the Class Representative. If there are objections, the Court will consider them. The Court may elect to move the final approval hearing to a different date or time in its sole discretion, without providing further notice to the Class. The date and time of the final approval hearing can be confirmed on this website.

If the Court approves the settlement and enters judgment, the Court’s order and notice of judgment will be available on the Settlement Documents page.

No. Class Counsel will answer any questions the Court may have. However, you are welcome to come to the final approval hearing at your own expense and ask the Court to speak. If you send an objection by mail, you do not have to come to the final approval hearing to talk about it, but you may do so if you like. You may also pay your own lawyer to attend, but that is not necessary.

You may ask the Court for permission to speak at the final approval hearing. You can attend (or hire a lawyer at your expense to attend on your behalf) either personally or virtually via https://www.sdcourt.ca.gov/virtualhearings.

If you are a Class Member and you do nothing, you will give up the rights explained in Question 13, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants related to the Lawsuit or for claims that in any way are related to the subject matter of the claims in this Lawsuit. You will not receive a Class Payment.

Visit the Settlement Documents page, where you will find the settlement agreement and other related documents. You may also call or write to the Settlement Administrator or Class Counsel using the information below.

Settlement Administrator:
Apex Class Action LLC
[Mailing address to be confirmed]
[Toll-free number to be confirmed]
[Email address to be confirmed]

Class Counsel:

Jack Day
Calvin Bryne
Day Bryne & McIntosh
129 West Wilson Street, Suite 105
Costa Mesa, CA 92627
jack@dbm.law
calvin@dbm.law

Paul Haines
Haines Law Group, APC
2155 Campus Drive, Suite 180
El Segundo, CA 90245
phaines@haineslawgroup.com

You may also view Court documents filed in this case by going to the Court’s website at https://www.sdcourt.ca.gov/sdcourt/generalinformation/accesscourtrecords and entering the case number for this case. You can also visit https://www.sdcourt.ca.gov/sdcourt/generalinformation/courtrecords2/viewacourtfile to request to personally review court documents. Do NOT telephone the Court to obtain information about the settlement.