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NOTICE OF PENDENCY OF CLASS ACTION:  Please be advised that your rights may be affected by the above-captioned class action lawsuit pending in this Court (the “Action”) if you (a) purchased or otherwise acquired Faraday Future Intelligent Electric Inc. (“Faraday” or the “Company”) securities between January 28, 2021 and April 14, 2022, both dates inclusive (the “Settlement Class Period”), and/or (b) beneficially owned and/or held the Class A common stock of Property Solutions Acquisition Corp. (“PSAC”) as of June 21, 2021 and were eligible to vote at PSAC’s July 20, 2021 special meeting and were allegedly damaged thereby (the “Settlement Class”).

NOTICE OF SETTLEMENT:  Please also be advised that the Lead Plaintiffs Byambadorj Nomin, Hao Guojun, Peihao Wang, and Shentao Ye (“Lead Plaintiffs” or “Plaintiffs”), on behalf of the Settlement Class (as defined in ¶1 below), have reached a proposed settlement of the Action for a total of $7.5 million in cash to settle all of the Plaintiffs’ and the Settlement Class’ known and unknown claims against Defendants on the following terms (the “Settlement”).

The Notice of Pendency and Proposed Settlement of Class Action (“Notice”) explains important rights you may have, including your possible receipt of cash from the Settlement.¹ Your legal rights will be affected whether or not you act.  Please read the Notice carefully!

1. Description of the Action and the Settlement Class:  The Notice relates to a proposed Settlement of a class action lawsuit pending against Faraday and the following Individual Defendants: Carsten Breitfeld, Zvi Glasman, Jordan Vogel, Aaron Feldman, and Yueting Jia (collectively, “Defendants”).  Defendants are collectively, with Plaintiffs, the “Settling Parties” or “Parties”.  The proposed Settlement, if approved by the Court, will apply to the following Settlement Class (the “Settlement Class”): (a) all persons and entities who purchased or otherwise acquired Faraday securities between January 28, 2021 and April 14, 2022, both dates inclusive, and/or (b) beneficially owned and/or held the Class A common stock of PSAC as of June 21, 2021 and were eligible to vote at PSAC’s July 20, 2021 special meeting and were allegedly damaged thereby.  Excluded from the Settlement Class are: (i) Defendants; (ii) current and former officers and directors of Faraday; (iii) members of the immediate family of each of the Individual Defendants (as defined in Item 404 of SEC Regulation S-K, 17 C.F.R. §229.404, Instructions (1)(a)(iii) & (1)(b)(ii)); (iv) all subsidiaries and affiliates of Faraday; (v) all persons, firms, trusts, corporations, officers, directors, and any other individual or entity in which any of the Defendants has a controlling interest; and (vi) the legal representatives, heirs, estates, agents, successors, or assigns of any person or entity described in the preceding five categories.  Also excluded from the Settlement Class is any Person who timely and validly seeks exclusion from the Settlement Class in accordance with the requirements set by the Court.  Anyone with questions as to whether or not they are excluded from the Settlement Class may call the Claims Administrator toll-free at (866) 274-4004.
2. Statement of Settlement Class’s Recovery:  Subject to Court approval, and as described more fully in ¶¶26-31, 47-53 in the Notice, Plaintiffs, on behalf of the Settlement Class, have agreed to settle all Released Plaintiffs’ Claims (as defined in ¶48 in the Notice) against Defendants and other Released Defendant Parties (as defined in ¶50 in the Notice) in exchange for a settlement payment of $7.5 million in cash (the “Settlement Amount”) to be deposited into an escrow account.  The Settlement Fund (less Taxes and Tax Expenses, Notice and Administration Expenses, and attorneys’ fees and litigation expenses and awards to the Lead Plaintiffs) will be distributed in accordance with a plan of allocation (the “Plan of Allocation”) that will be approved by the Court and will determine how the Settlement Fund shall be distributed to members of the Settlement Class. The Plan of Allocation is a basis for determining the relative positions of Settlement Class Members for purposes of allocating the Settlement Fund.  The proposed Plan of Allocation is included in the Notice, and may be modified by the Court without further notice.
3. Statement of Average Distribution Per Share:  The Settlement Fund consists of the $7.5 million Settlement Amount plus interest earned.  Assuming all potential Settlement Class Members elect to participate, the estimated average recovery is $0.07 per damaged share before fees and expenses.  Settlement Class Members may recover more or less than this amount depending on, among other factors, the aggregate value of the Recognized Losses represented by valid and acceptable Claim Forms as explained in the Plan of Allocation below; when their shares were purchased or acquired and the price at the time of purchase or acquisition; whether the shares were sold, and if so, when they were sold and for how much.  In addition, the actual recovery of Settlement Class Members may be further reduced by the payment of fees and costs from the Settlement Fund, as approved by the Court.
4. Statement of the Parties’ Position on Damages:  Defendants deny all claims of wrongdoing, deny that they engaged in any wrongdoing, deny that they are liable to Plaintiffs and/or the Settlement Class and deny that Plaintiffs or other members of the Settlement Class suffered any injury.  Moreover, the Parties do not agree on the amount of recoverable damages if Plaintiffs were to prevail on each of the claims.  The issues on which the Parties disagree include, but are not limited to: (1) whether the statements made or facts allegedly omitted were material, false or misleading; (2) whether the statements were made with intent to deceive, manipulate, or defraud investors; (3) whether Defendants are otherwise liable under the securities laws for those statements or omissions or any alleged scheme to defraud; and (4) whether all or part of the damages allegedly suffered by members of the Settlement Class were caused by economic conditions or factors other than the allegedly false or misleading statements or omissions.
5. Statement of Attorneys’ Fees and Expenses Sought:  Lead Counsel will apply to the Court, on behalf of all Plaintiffs’ Counsel, for an award of attorneys’ fees from the Settlement Fund of no more than 33.3% of the Settlement Amount, plus interest earned at the same rate and for the same period as earned by the Settlement Fund.  In addition, Lead Counsel also will apply to the Court for payment from the Settlement Fund for Plaintiffs’ Counsel’s litigation expenses (reasonable expenses or charges of Plaintiffs’ Counsel in connection with commencing and prosecuting the Action), in a total amount not to exceed $440,000 plus interest earned at the same rate and for the same period as earned by the Settlement Fund.  In addition, Lead Counsel may apply for awards to Lead Plaintiffs in connection with its members’ representation of the Settlement Class in an amount not to exceed $20,000.00, combined.  If the Court approves Lead Counsel’s fee and expense application, the estimated average cost per damaged share is $0.03. The estimated average recovery, after deducting attorneys’ fees and expenses, administrative costs, and Class Representative awards of reasonable costs and expenses (if approved by the Court), is approximately $0.04 per damaged share.  
6. Identification of Attorneys’ Representatives:  Plaintiffs and the Settlement Class are being represented by Pomerantz LLP (“Pomerantz”) and Wolf Haldenstein Adler Freeman & Herz LLP (“Wolf Haldenstein”) as Co-Lead Counsel and Hao Law Firm Beijing Hao Junbo Law Firm and The Rosen Law Firm, P.A. (“Rosen”) as Additional Counsel. Any questions regarding the Settlement should be directed to Austin Van, Esq. at Pomerantz LLP, 600 Third Avenue, 20th Floor, New York, NY 10016, (212) 661-1100, avan@pomlaw.com.

YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT

¹ All capitalized terms used in the Notice that are not otherwise defined herein shall have the meanings provided in the Stipulation of Settlement dated October 5, 2023, which is available on the Important Documents page.