If you purchased or otherwise acquired Workhorse Group, Inc. common stock (trading symbol "WKHS") between March 10, 2020, and May 10, 2021, inclusive, your rights may be affected by a class action settlement.

SANTA ANA, Calif., March 7, 2023

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SAM FARRAR, Individually and on Behalf of All Others Similarly Situated, Plaintiff, v. WORKHORSE GROUP, INC., DUANE HUGHES, STEVE SCHRADER, ROBERT WILLISON, and GREGORY ACKERSON, Defendants. ARIVA.DE Börsen-Geflüster Kurse Workhorse Group 0,1975 $ +0,77%

Case No. 2:21-cv-02072-CJC-PVC   CLASS ACTION   SUMMARY NOTICE OF (I) PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT; (II) SETTLEMENT HEARING; AND (III) MOTION FOR ATTORNEYS' FEES AND EXPENSES

TO: ALL PERSONS WHO PURCHASED OR OTHERWISE ACQUIRED WORKHORSE GROUP, INC. COMMON STOCK (TRADING SYMBOL "WKHS") BETWEEN MARCH 10, 2020 AND MAY 10, 2021, INCLUSIVE

YOU ARE HEREBY NOTIFIED, pursuant to an Order of the United States District Court for the Central District of California, that a hearing will be held on July 24, 2023, at 1:30 p.m., before the Honorable Cormac J. Carney in Courtroom 9B of the Ronald Reagan Federal Building and United States Courthouse, 411 West Fourth Street, Santa Ana, CA 92701, for the purpose of determining:
(1) whether the proposed Settlement for the sum of $35,000,000 ($15,000,000 in cash and $20,000,000 in shares of Workhorse common stock) should be approved by the Court as fair, reasonable, and adequate; (2) whether, after the hearing, this Action should be dismissed with prejudice pursuant to the terms and conditions set forth in the Stipulation of Settlement dated January 13, 2023; (3) whether the proposed Plan of Allocation is fair, reasonable, and adequate and should be approved; and (4) whether the application of Lead Counsel for the payment of attorneys' fees and reimbursement of expenses incurred in this Action, and an application of Lead Plaintiff and Additional Plaintiff for compensatory awards, should be approved.

If you purchased Workhorse Group, Inc. ("Workhorse" or the "Company") common stock (trading symbol "WKHS") between March 10, 2020 and May 10, 2021, inclusive, your rights may be affected by the Settlement of this Action. Please visit the website at www.WorkhorseSecuritiesLitigation.com to obtain copies of the Notice of Pendency and Proposed Settlement ("Notice") and the Proof of Claim and Release. You may also obtain copies of these documents by writing to info@WorkhorseSecuritiesLitigation.com or by calling the Claims Administrator toll-free at 1-844-787-0160. The Notice contains details about this Action and Settlement, including what you must do to file a Proof of Claim, exclude yourself from the Settlement, or object to the Settlement. If you are a Settlement Class Member, in order to share in the distribution of the Net Settlement Fund, you must submit a Proof of Claim and Release electronically by, or mail it postmarked no later than, July 3, 2023, establishing that you are entitled to recovery.

If you desire to be excluded from the Settlement Class, you must submit a Request for Exclusion postmarked by July 3, 2023, in the manner and form explained in the detailed Notice referred to above. All Members of the Settlement Class who have not timely and validly requested exclusion from the Settlement Class will be bound by any judgment entered in the Action pursuant to the terms and conditions of the Stipulation of Settlement. Please note that if you exclude yourself from the Settlement Class and decide to pursue your own action individually, you may not be able to pursue certain claims due to the expiration of certain applicable statutes of repose.

Your objection(s) must be postmarked on or before July 3, 2023, to the Court, Lead Counsel Kahn Swick & Foti, LLC, and Counsel for Defendants, at the following addresses:

COURT:

Clerk of the Court
Ronald Reagan Federal Building and United States Courthouse
411 West 4^th Street
Santa Ana, CA 92701

LEAD COUNSEL:

Lewis S. Kahn
KAHN SWICK & FOTI, LLC
1100 Poydras Street, Suite 960
New Orleans, LA 70163

Lead Counsel for Lead Plaintiff Timothy M. Weis,
Additional Plaintiff Angelo Federico, and the Settlement Class

FOR DEFENDANTS WORKHORSE GROUP, INC. AND GREGORY ACKERSON:

John P. Stigi III
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
1901 Avenue of the Stars, Suite 1600
Los Angeles, CA 90067

Counsel for Defendants Workhorse Group, Inc. and Gregory Ackerson

FOR DEFENDANTS DUANE HUGHES, STEVE SCHRADER, AND ROBERT WILLISON:

Richard H. Zelichov
KATTEN MUCHIN ROSENMAN LLP
2029 Century Park East, Suite 2600
Los Angeles, CA 90067

Counsel for Defendants Duane Hughes, Steve Schrader, and Robert Willison

PLEASE DO NOT CONTACT THE COURT OR THE CLERK'S OFFICE REGARDING THIS NOTICE. If you have any questions about the Settlement, you may contact Lead Counsel at the address listed above.

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SOURCE Kahn Swick & Foti, LLC