Camden Land Subsidence Class Action

Settlement Notice to Group Members

1. Pursuant to s 175 and 176 of the Civil Procedure Act 2005 (NSW) (the Act), the form and content of the notice to Group Members of proposed settlement attached as Schedule A to these orders (Group Member Notice) and the newspaper notice in Schedule B to these orders (Newspaper Notice) be approved.

2. The Group Member Notice and annexed forms may be amended by the solicitors for the Plaintiff, Mayweathers, before distribution to provide up-to-date cost information and update or correct any postal, website, email address, telephone number or any typesetting or typographical information.

3. Pursuant to s 176(2) of the Act, the Group Member Notice is to be distributed to Group Members of the proceeding in accordance with the following procedure on or before 20 August 2026:
(a) the client liaison team at Omni Bridgeway Limited ACN 067 298 088 (Omni Bridgeway) is to cause the Group Member Notice to be sent to each person that is recorded as being a registered member of the ‘Spring Farm Litigation Funding Scheme’ (as it was then known) (Omni Register):
(i) first, by email to the email address recorded in the Omni Register; and
(ii) second, to the extent that (A) a Group Member is listed in the Omni Register without an email address, or (B) a bounce back message is received to an email sent pursuant to order 3(a)(i), by ordinary prepaid post, to the postal addresses recorded in the Omni Register,
(b) to the extent that a Group Member Notice has not been delivered pursuant to orders 3(a)(i) or 3(a)(ii), the client liaison team at Omni Bridgeway is to cause the Group Member Notice to be sent by ordinary prepaid post to all Group Members (of whom they are otherwise aware);
(c) the Plaintiff is to cause an advertisement in the terms of the Newspaper Notice to be published in the legal notices or equivalent section in one weekday edition of The Sydney Morning Herald;
(d) the Group Member Notice is to be displayed on:
(i) the webpage hosted by the Plaintiff’s solicitors in relation to the proceeding at https://www.mayweathers.com.au/spring-farm;
(ii) the webpage hosted by Omni Bridgeway in relation to the Proceeding at https://portal.omnibridgeway.com/spring-farm.
(e) the Registry of the Supreme Court of New South Wales shall display the Group Member Notice on the Court’s website.

Registration and Objection

4. Pursuant to s 162(1) and/or 183 of the Act, 18 September 2026 be fixed as the date by which a Group Member:
(a) must register to participate in the proposed settlement; or
(b) must object to the proposed settlement, or any aspect of it.

5. Pursuant to sections 162(2) and/or 183 of the Act:
(a) any Group Member wishing to apply to participate in the proposed settlement who has not already applied for and been accepted as a member of the scheme then known as the ‘Spring Farm Litigation Funding Scheme’, must, before the deadline specified in Order 4:
(i) complete and submit the online registration form available on the webpage hosted by Omni Bridgeway in relation to the Proceeding at https://portal.omnibridgeway.com/spring-farm; or
(ii) complete and return the hard copy registration form at Annexure B to the Group Member Notice; or
(b) any Group Member wishing to object to the proposed settlement, or any aspect of it, must before the deadline specified in Order 4:
(i) file a completed ‘Notice of Objection’ in the form attached as Annexure C to the to the Group Member Notice;
(ii) file any evidence and written submissions on which the Group Member relies in support of the Notice of Objection, in the registry of the Supreme Court of New South Wales, and send a copy of these documents to Omni Bridgeway.

6. The costs of and incidental to the procedure set out in order 5 above (including, without limitation, costs incurred in addressing enquiries by Group Members and members of the public in relation to the Group Member Notice) shall be paid in the first instance by the Plaintiff but shall be costs recoverable from the proposed settlement, if approved.

7. The solicitors for the parties to the proceeding have leave to inspect the court file and to copy any notices of objection and supporting materials filed with the Court.

Hearing of Approval Application

8. By 12pm 17 August 2026 the Plaintiff is to file a Notice of Motion seeking approval of the proposed settlement pursuant to s 173(1) of the Act, together with consequential orders including:
(a) orders under s 173(2) of the Act in relation to the approval of proposed deductions from the settlement sum and the approval of a proposed Settlement Distribution Scheme;
(b) orders under s 179 of the Act; and
(c) orders providing that any Group Member who is not the owner of an Eligible Property as defined in the Settlement Distribution Scheme, or who has not registered prior to the date in Order 4(a) above shall not be permitted to seek any benefit pursuant to the settlement or the Settlement Distribution Scheme

(Approval Application).

9. The hearing of the Approval Application be listed before Justice Chen at 10am on 13 October 2026.

10. Omni Bridgeway and/or Omni Bridgeway (Fund 5) Australian Invt. Pty Limited ACN 635 083 984 (each, Funder) has leave to intervene and be heard in relation to the Approval Application.

11. Mayweathers has leave to intervene and be heard in relation to the Approval Application.

12. Pursuant to section 183 of the Act, pages [1] to [59] of Exhibit AJA-13 being the Annexure marked “Annexure A” to the Affidavit of Andre Joseph Adams sworn 11 August 2026 is to be treated as confidential and is not be published, disclosed or made available for inspection, other than by leave of the Court, to any person or entity, except to:
(a) the Court;
(b) the Plaintiff and his legal representatives;
(c) Group Members, other than those who have opted-out of the proceedings as at the date of these orders;
the Funder and its legal representatives; and
(e) Defendants and their legal representatives.

13. Pursuant to section 183 of the Act, pages [101] to [103] of Exhibit AJA-13 being a portion of the Annexure marked “Annexure E” to Affidavit of Andre Joseph Adams sworn 11 August 2026 is to be treated as confidential and is not be published, disclosed or made available for inspection, other than by leave of the Court, to any person or entity, except to:
(a) the Court;
(b) Group Members, other than those who have opted-out of the proceedings as at the date of these orders;
(c) the Plaintiff and his legal representatives, and
(d) the Funder and its legal representatives.

14. The hearing listed to commence on 12 August 2026 be vacated.

15. The proceedings be listed for directions at 9:30am on 18 August 2026 before Justice Chen for directions to be given with respect to the hearing of the Approval Application.

16. The parties to provide to Justice Chen’s Associate by 12:00pm on 17 August 2026, a copy of the Notice of Motion as filed and agreed short minutes of order, or to the extent there is disagreement, competing short minutes of order.

17. Liberty to apply on three days’ notice.