Frequently Asked Questions

BASIC INFORMATION

1. Why is the Notice being provided?

The Court directed that the Notice be provided because you have a right to know about a proposed Settlement that has been reached in this class action lawsuit and about all of your options before the Court decides whether to grant final approval of the Settlement. If the Court approves the Settlement, and after objections or appeals, if any, are resolved, the Claims Administrator appointed by the Court will distribute the payments that the Settlement allows. The Notice explains the lawsuit, the Settlement, your legal rights, what payments are available, who is eligible for them, and how to get them.

The Court in charge of this case is the District Court of Dallas County, Texas, 134th Judicial District. The case is known as Gleason et al. v. Methodist Hospitals of Dallas d/b/a Methodist Health System, et al., Cause No. DC-22-14875 (the “Lawsuit”). The people who filed the Lawsuit are called the Plaintiffs and the entities they sued, Methodist Hospitals of Dallas d/b/a Methodist Hospital Systems, MedHealth d/b/a Methodist Medical Group, and Methodist McKinney Hospital are called the Defendants.

2. What is this lawsuit about?

The Lawsuit claims the Defendants were responsible for not preventing the Data Security Incident and asserts claims for: negligence, negligence per se, breach of implied contract, breach of fiduciary duty, public disclosure of private facts, and unjust enrichment. The Lawsuit seeks, among other things, payment for persons who may have been injured by the Data Security Incident.

Defendants have denied and continue to deny all of the claims made in the Lawsuit, as well as all charges of wrongdoing or liability against them.

3. What is a class action?

In a class action, one or more people called Class Representatives (in this case, Sandra Gleason, Robin Robinson Jestice, Christina Reining, Paige Segovia, Vicki Lacy, and Virginia Standefer) sue on behalf of people who are alleged to have similar claims. Together, all of these people are called a Class. One Court and one judge resolves the issues for all Class members, except for those who exclude themselves from the Settlement Class.

4. Why is there a settlement?

The Court did not decide in favor of the Plaintiffs or Defendants. Instead, the Plaintiffs negotiated a settlement with Defendants that allows both the Plaintiffs and Defendants to avoid the risks and costs of lengthy and uncertain litigation and the uncertainty of a trial and appeals. It also allows Settlement Class Members to obtain payment and credit monitoring services without further delay. The Class Representatives and their attorneys think the Settlement is best for all Settlement Class Members.

WHO IS INCLUDED IN THE SETTLEMENT?

5. How do I know if I am part of the Settlement?

You are part of this Settlement as a Settlement Class Member if you previously received a notice letter from MMH in or around August 2022 pertaining to the Data Security Incident.

6. Are there exceptions to being included in the Settlement?

Yes. Specifically excluded from the Settlement Class are: (i) Defendants; (ii) any entity in which Defendants have a controlling interest, is a parent or subsidiary, or which is controlled by Defendants; and (iii) the affiliates, legal representatives, attorneys, heirs, predecessors, successors, and assigns of Defendants. Also excluded are the judges and court personnel in this case and any members of their immediate families.

THE SETTLEMENT BENEFITS—WHAT YOU GET IF YOU QUALIFY

7. What does the Settlement provide?

The Settlement provides for the creation of a $985,000 Settlement Fund that will provide payments and credit monitoring services to people who submit valid claims, as well as cover administrative expenses, court-approved attorneys’ fees and costs, and plaintiff service awards.

Settlement Class Members can claim either:

1. Up to $5,000 each for Reimbursement of Documented Out-of-Pocket Losses (Question 8, below) and up to $100 for Lost Time (Question 8, below); OR
2. A pro rata Cash Payment (Question 8, below).

Settlement Class Members can also make a claim for two-years of credit monitoring and identity protection services (Question 9, below).

8. What payments are available?

Each Settlement Class Member may submit a claim to receive:

1. reimbursement of up to $5,000 for reimbursement of documented out-of-pocket losses and reimbursement of up to $100 for lost time; OR
2. a pro rata cash payment.

Out-of-Pocket Losses

Settlement Class Members may submit a claim for the following types of documented out-of-pocket losses resulting from the Data Security Incident, including, but not limited to:

• costs associated with accessing or freezing/unfreezing credit reports with any credit-reporting agency;


• other miscellaneous expenses incurred related to any Documented Out-of-Pocket Losses such as notary, fax, postage, copying, mileage, and long-distance telephone charges;


• credit monitoring or other expenses related to preventing identity theft or fraud related to the Data Security Incident.

Claims for reimbursement of Documented Out-of-Pocket Losses must be supported by providing the Claims Administrator documents necessary to evaluate the claim, including:

1. documentation supporting the unreimbursed cost, loss, or expenditure; and


2. a brief description of the documentation describing the nature of the cost, loss, or expenditure, if the nature of the cost, loss, or expenditure is not apparent from the documentation alone.

Documentation can include receipts or other documentation not “self-prepared” by the Settlement Class Member that documents the costs incurred. “Self-prepared” documents, such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but can be considered to add clarity or support to other submitted documentation.

Lost Time

Settlement Class Members may also make a claim for up to four (4) hours of lost time spent dealing with the Data Incident, to be paid at $25 per hour. Such time can include:

• time spent dealing with researching and/or reversing fraudulent charges;


• rescheduling medical appointments and/or finding alternative medical care and treatment;


• retaking or submitting to medical tests;


• locating medical records;


• retracing medical history; and/or


• any other demonstrable form of disruption to medical care and treatment, but only if at least one full hour was spent.

To make a claim for Lost Time, Settlement Class Members must provide an attestation and a brief description of:

1. the actions taken in response to receiving notice of the Data Security Incident;
2. the time associated with those actions.

Pro Rata Cash Payment

In lieu of submitting a claim for Document Out-of-pocket Losses and Lost Time, Settlement Class Members may claim a pro rata cash payment. The pro rata cash payment is estimated to be $50. It will increase or decrease based on the amount of money left in the Settlement Fund after payment of administration costs, Court-approved attorneys’ fees and costs, approved claims for Document Out-of-Pocket Losses, approved claims for Lost Time, and approved claims for credit monitoring and identity theft protection services.

9. What credit monitoring and identity theft protections are available?

Settlement Class Members who submit a valid claim are eligible to enroll in a total of two years of credit monitoring and identity protection services, including $1,000,000 in identity theft insurance.

More details are provided in the Settlement Agreement, which is available here.

HOW TO GET BENEFITS—SUBMITTING A CLAIM FORM

10. How do I get benefits from the Settlement?

To ask for a payment, you must complete and submit a Claim Form. Claim Forms can be submitted online, here. A paper copy of the Claim Form is available for download here, or you may request one be sent by mail by calling (866) 675-2973. Read the instructions carefully, fill out the Claim Form, and mail it to:

MMH Data Incident
Claims Administrator
PO Box 25413
Santa Ana, CA 92799

Claim forms must be submitted online or postmarked no later than May 27, 2025.

11. How will claims be decided?

The Claims Administrator will initially decide whether the information provided on a Claim Form is complete and valid. The Claims Administrator may require additional information from any claimant. If the required information is not provided by May 27, 2025, the claim will be considered invalid and will not be paid.

Additional information regarding the claims process can be found in Section 2.7 of the Settlement Agreement, available here.

12. When will I get my payment?

The Court will hold a Final Fairness Hearing at 8:30 a.m. (CST) on June 27, 2025, to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals. It is always uncertain whether any appeals can be resolved favorably and resolving them can take time. It also takes time for all the Claim Forms to be processed, depending on the number of claims submitted and whether any appeals are filed. Please be patient.

REMAINING IN THE SETTLEMENT

13. Do I need to do anything to remain in the Settlement?

You do not have to do anything to remain in the Settlement, but if you want a cash payment and/or credit monitoring services you must submit a Claim Form online or postmarked by May 27, 2025.

14. What am I giving up as part of the Settlement?

If the Settlement becomes final, you will give up your right to sue Defendants for the claims being resolved by this Settlement. The specific claims you are giving up against Defendants are described in Section 6 of the Settlement Agreement. You will be “releasing” Defendants, and all related people or entities as described in Section 6 of the Settlement Agreement. The Settlement Agreement is available here.

The Settlement Agreement describes the released claims with specific descriptions, so read it carefully. If you have any questions about what this means you can talk to the law firms listed in Question 18 for free or you can, of course, talk to your own lawyer at your own expense.

EXCLUDING YOURSELF FROM THE SETTLEMENT

If you do not want a payment from this Settlement, but you want to keep the right to sue Defendants about issues in the Litigation, then you must take steps to remove yourself from the Settlement Class. This is called excluding yourself from – or is sometimes referred to as “opting out” of – the Settlement Class.

15. If I exclude myself, can I still get payment from the Settlement?

No. If you exclude yourself from the Settlement, you will not be entitled to any benefits of the Settlement, but you will not be bound by any judgment in this case.

16. If I do not exclude myself, can I sue MMH for the same thing later?

No. Unless you exclude yourself from the Settlement, you give up any right to sue Defendants for the claims that this Settlement resolves. You must exclude yourself from the Settlement Class to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. If you exclude yourself, do not submit a Claim Form to ask for a payment.

17. How do I get out of the Settlement?

To exclude yourself from the Settlement, you must send a letter by mail stating that you want to be excluded from the Settlement in Gleason et al. v. Methodist Hospitals of Dallas d/b/a Methodist Health System et al., Cause No. DC-22-14875. Your letter must also include your name, address, and signature. You must mail your exclusion request postmarked no later than April 28, 2025, to:

MMH Data Incident
Claims Administrator
PO Box 25413
Santa Ana, CA 92799

THE LAWYERS REPRESENTING YOU

18. Do I have a lawyer in this case?

Yes. The Court appointed William Federman of Federman & Sherwood, A. Brooke Murphy, of the Murphy Law Firm, Joseph M. Lyon of The Lyon Firm, Brian Gudmundson of Zimmerman & Reed, LLP, Danielle Perry of Mason LLP, and Joe Kendell of Kendall Law Group, PLLC, to represent you and other Settlement Class Members. These lawyers are called Class Counsel. You will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.

19. How will Class Counsel be paid?

If the Settlement is approved and becomes final, Class Counsel will ask the Court to award attorneys’ fees in the amount of $328,050 (33% of the Settlement Fund) and costs not to exceed $60,000. Class Counsel will also request approval of an incentive award of $1,500 for the Class Representatives. If approved, these amounts will be paid by the Settlement Fund.

OBJECTING TO THE SETTLEMENT

20. How do I tell the Court that I do not like the Settlement?

If you are a Settlement Class Member, you can object to the Settlement if you do not like it or a portion of it. You can give reasons why you think the Court should not approve the Settlement. The Court will consider your views before making a decision. To object, you must file with the Court and mail copies to Class Counsel and MMH’s Counsel a written notice stating that you object to the Settlement in Gleason et al. v. Methodist Hospitals of Dallas d/b/a Methodist Health System et al., Cause No. DC-22-14875.

Your objection must include:

1. the name or caption of this Litigation (Gleason et al. v. Methodist Hospitals of Dallas d/b/a Methodist Health System et al., Cause No. DC-22-14875);


2. your full name, address, telephone number, and e-mail address (if any);


3. information identifying you as a Settlement Class Member, including proof that you are a member of the Settlement Class (i.e., that you received a notice letter of the Data Security Incident);


4. a written statement of all grounds for the objection, accompanied by any legal support for the objection you believe is applicable;


5. the identity of all counsel representing you in your objection, if any;


6. a statement whether you or your counsel will appear at the Final Fairness Hearing;


7. a statement identifying all class action settlements you have objected to in the previous 5 years; and


8. your signature and the signature of your duly authorized attorney or other duly authorized representative, if any.

Your objection must be filed with the Clerk of the District Court for Dallas County, 134th Judicial District, 600 Commerce Street, 6th Floor West, Dallas, Texas 75202 no later than April 28, 2025. You must also mail copies of your objection to Class Counsel and Defendants’ Counsel postmarked no later than April 28, 2025 to all of the addresses below.

21. What is the difference between objecting to and excluding myself from the Settlement?

Objecting is telling the Court that you do not like something about the Settlement. Excluding yourself is telling the Court that you do not want to be part of the Class in this Settlement. If you exclude yourself from the Settlement, you have no basis to object or submit a Claim Form because the Settlement no longer affects you.

THE COURT’S FINAL FAIRNESS HEARING

22. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Fairness Hearing at 8:30 a.m. (CST) on June 27, 2025, in the District Court for Dallas County, 134th Judicial District, 600 Commerce Street, 6th Floor West, Dallas, Texas 75202. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. The Court will take into consideration any properly-filed written objections and may also listen to people who have asked to speak at the hearing (see Question 20). The Court will also decide whether to approve fees and costs for Class Counsel and service award for the Class Representatives.

23. Do I have to come to the Final Fairness Hearing?

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you file an objection, you do not have to come to Court to talk about it. You may also hire your own lawyer to attend, at your own expense, but you are not required to do so.

24. May I speak at the Final Fairness Hearing?

Yes, you may ask the Court for permission to speak at the Final Fairness Hearing. To do so, you must follow the instructions provided in Question 20 above. You cannot speak at the hearing if you exclude yourself from the Settlement.

IF YOU DO NOTHING

25. What happens if I do nothing?

If you do nothing, you will not receive any compensation from this Settlement. If the Court approves the Settlement, you will be bound by the Settlement Agreement and the Release. This means you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants or related parties regarding the issues involved in the Lawsuit, resolved by this Settlement, and released by the Settlement Agreement.

GETTING MORE INFORMATION

26. Are more details about the Settlement available?

Yes. This website and the Notice summarize the proposed Settlement. More details are in the Settlement Agreement, which is available here. You may contact the Claims Administrator by calling (866) 675-2973, or writing to the MMH Data Incident, Claims Administrator, PO Box 25413, Santa Ana, CA 97299.

Please do not call the Court or the Clerk of the Court for additional information.
They cannot answer any questions regarding the Settlement or the Lawsuit