Notice of Pendency and Proposed Settlement of Stockholder Class Action Involving All Persons Who Held Shares of Northern Genesis Acquisition Corp Class A Common Stock as of April 21, 2021

SEATTLE, Oct. 16, 2026 /PRNewswire/ -- JND Legal Administration--

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

SUMMARY NOTICE OF PENDENCY AND PROPOSED
SETTLEMENT OF STOCKHOLDER CLASS ACTION,
SETTLEMENT HEARING, AND RIGHT TO APPEAR

TO:All persons who held shares of Northern Genesis Acquisition Corp ("NGA" or the "Company") Class A Common Stock, who held such stock as of April 21, 2021 (the "Redemption Deadline"), either of record or beneficially, and who elected not to redeem all of such shares, including their successors-in-interest who obtained their shares by operation of law, but excluding the Excluded Persons.Excluded Persons are (i) Defendants and the members of Defendants' immediate families; (ii) any Person, firm, trust, corporation, or any entity related to or affiliated with any of the foregoing individuals, or in which any of the foregoing individuals or entities has a controlling interest; and (iii) the legal representatives, heirs, successors, or assignees of any such Excluded Persons —in each case, only to the extent such Persons or entities held shares of NGA Class A Common Stock as of the Redemption Deadline.Excluded Persons also include any trusts, estates, entities, or accounts that held shares of NGA Class A Common Stock for the benefit of any Excluded Persons.¹

THIS SUMMARY NOTICE WAS AUTHORIZED BY THE COURT.IT IS NOT A LAWYER SOLICITATION.PLEASE READ THIS SUMMARY NOTICE CAREFULLY.YOUR RIGHTS MAY BE AFFECTED BY A CLASS ACTION LAWSUIT PENDING IN THE COURT.

YOU ARE HEREBY NOTIFIED, pursuant to an Order of the Court of Chancery of the State of Delaware ("Court") and Delaware Court of Chancery Rule 23 that: (i) the above-captioned action (the "Action") is pending in the Court and has been preliminary certified as a class action on behalf of the Class defined above; and (ii) Plaintiffs and Defendants have reached a proposed settlement of the Action for $4,000,000.00 in cash (the "Settlement Amount") as set forth in the Stipulation (the "Settlement"), a copy of which is available at www.LionElectricStockholdersLitigation.com. The Settlement, if approved by the Court, will resolve all claims in the Action.

A hearing (the "Settlement Hearing") will be held on December 1, 2026, at 11:00 a.m., before The Honorable Nathan A. Cook, Vice Chancellor, at the Court of Chancery of the State of Delaware, New Castle County, Leonard L. Williams Justice Center, 500 North King Street, Wilmington, Delaware 19801, to, among other things: (i) determine whether to finally certify the Class for settlement purposes only, pursuant to Court of Chancery Rules 23(a) and 23(b)(1); (ii) determine whether Plaintiffs and Plaintiffs' Lead Counsel have adequately represented the Class, and whether they should be finally appointed as Class Representatives and Class Counsel, respectively, for the Class; (iii) determine whether the proposed Settlement should be approved as fair, reasonable, and adequate to Plaintiffs and the other Class Members; (iv) determine whether the proposed Final Order and Judgment approving the Settlement, dismissing with prejudice the claims asserted against Defendants in the Action, and granting the Releases provided under the Stipulation should be entered; (v) determine whether the proposed Plan of Allocation of the Net Settlement Fund is fair and reasonable, and should therefore be approved; (vi) determine whether and in what amount any award of attorneys' fees and litigation expenses to Plaintiffs' Counsel ("Fee and Expense Award") should be paid out of the Settlement Fund, including any representative party awards to Plaintiffs to be paid solely from any Fee and Expense Award; and (vii) consider any other matters that may properly be brought before the Court in connection with the Settlement. Any updates regarding the Settlement Hearing, including any changes to the date, time, or format of the hearing or updates regarding remote or in-person appearances at the hearing, will be posted to the Settlement website, www.LionElectricStockholdersLitigation.com.

If you are a member of the Class, your rights will be affected by the pending Action and the Settlement, and you may be entitled to share in the Net Settlement Fund. If you have not yet received the full Notice of Pendency and Proposed Settlement of Stockholder Class Action, Settlement Hearing, and Right to Appear (the "Notice") and Proof of Claim and Release Form (the "Proof of Claim and Release"), you may obtain copies by contacting the Settlement Administrator by mail at Lion Electric Stockholders Litigation, c/o JND Legal Administration, P.O. Box 91250, Seattle, WA 98111; by telephone at 1-855-961-0957; or by email at [email protected]. A copy of the Notice and Proof of Claim and Release can also be downloaded from the Settlement website, www.LionElectricStockholdersLitigation.com. All Class Members are strongly encouraged to carefully review the full Notice and to complete a Proof of Claim and Release.

The Class is a non-"opt-out" class pursuant to Delaware Court of Chancery Rules 23(a) and 23(b)(1). Accordingly, Class Members will be bound by any judgments or orders entered by the Court in the Action pursuant to the terms and conditions of the Stipulation.

If the Settlement is approved by the Court and the Effective Date occurs, the Net Settlement Fund will be distributed on a pro rata basis to eligible Class Members in accordance with the proposed Plan of Allocation stated in the Notice or such other plan of allocation as is approved by the Court. To be eligible to receive a payment from the Settlement, you must be a member of the Class and submit a Proof of Claim and Release postmarked (if mailed), or online, no later than January 30, 2027, in accordance with the instructions set forth in the Proof of Claim and Release. If you are a Class Member and do not submit a proper Proof of Claim and Release, you will not be eligible to share in the Settlement proceeds, but you will nevertheless be bound by any judgments or orders entered by the Court in the Action.

Any objections to the Settlement, the proposed Plan of Allocation, or Plaintiffs' Counsel's application for the Fee and Expense Award, including Plaintiffs' application for Incentive Awards, must be filed with the Register in Delaware Court of Chancery and delivered to Plaintiffs' Lead Counsel and Defendants' Counsel such that they are received no later than November 13, 2026, in accordance with the instructions set forth in the Notice.

Please do not contact the Court or the Office of the Register in Chancery regarding this Summary Notice.All questions about this Summary Notice, the proposed Settlement, or your eligibility to participate in the Settlement should be directed to the Settlement Administrator or Plaintiffs' Lead Counsel.

Requests for the Notice and Proof of Claim and Release should be made to the Settlement Administrator:

Lion Electric Stockholders Litigation
c/o JND Legal Administration
P.O. Box 91250
Seattle, WA 98111

Telephone: 1-855-961-0957
Email: [email protected]
Website: www.LionElectricStockholdersLitigation.com

Inquiries, other than requests for the Notice and Proof of Claim and Release, should be made to Plaintiffs' Lead Counsel:

Christine M. Mackintosh
Grant & Eisenhofer P.A.
123 Justison Street
7th Floor
Wilmington, DE 19801

Telephone: (302) 622-7000
Email: [email protected]

Erik W. Luedeke
Robbins Geller Rudman & Dowd LLP
655 W. Broadway
Suite 1900
San Diego, CA 92101

Telephone: (619) 231-1058
Email: [email protected]

Gregory E. Del Gaizo
Robbins LLP
5060 Shoreham Place
Suite 300
San Diego, CA 92122

Telephone: (619) 525-3990
Email: [email protected]

Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957

BY ORDER OF THE COURT
OF CHANCERY OF THE
STATE OF DELAWARE

¹ Any capitalized terms used in this Summary Notice that are not otherwise defined in this Summary Notice shall have the meanings given to them in the Stipulation and Agreement of Compromise, Settlement, and Release between the Parties, dated August 26, 2026 (the "Stipulation"). A copy of the Stipulation is available at the Settlement website, www.LionElectricStockholdersLitigation.com.

SOURCE JND Legal Administration