Lepore, et al. v. Affiliated Dermatologists & Dermatologic Surgeons, P.A.

1. Why is this Notice being provided?

   The Court authorized this Notice because you have the right to know about the Settlement of this class action lawsuit and about all of your rights and options before the Court decides whether to grant final approval to the Settlement. This Notice explains the lawsuit, the Settlement, your legal rights, what Settlement Class Member Benefits are available, who is eligible for the Settlement Class Member Benefits, and how to get them.

   The Honorable Rosemary E. Ramsay of the Superior Court of New Jersey, Morris County is overseeing this class action. The lawsuit is known as Lepore, et al. v. Affiliated Dermatologists & Dermatologic Surgeons, P.A., Case No. MRS-L-001091-24 (“lawsuit”). The individuals who filed this lawsuit are called the “Plaintiffs” and the company sued, Affiliated Dermatologists & Dermatologic Surgeons, P.A., is called the “Defendant.”

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2. What is this lawsuit about?

   The Plaintiffs filed this lawsuit against the Defendant on behalf of themselves and all others similarly situated involving a Data Incident discovered on or about March 5, 2024, by Defendant and resulting in potential unauthorized access to Settlement Class Members’ Private Information. The Private Information includes but is not limited to one or more of the following: dates of birth, Social Security numbers, medical treatment information, health insurance claims information, driver’s license numbers, passport numbers, and any other type of non-public personally identifiable information or protected health information.

   Defendant denies the legal claims and denies any wrongdoing or liability. The Court has not made any determination of any wrongdoing by Defendant, or that any law has been violated. Instead, the Plaintiffs and Defendant have agreed to a settlement to avoid the risk, cost, and time of continuing the lawsuit.

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3. Why is there a Settlement?

   The Plaintiffs and Defendant do not agree about the legal claims made in this lawsuit. The lawsuit has not gone to trial, and the Court has not decided in favor of the Plaintiffs or Defendant. Instead, the Plaintiffs and Defendant have agreed to settle the lawsuit. The Class Representatives, Defendant, and their lawyers believe the Settlement is best for the Settlement Class because of the Settlement Class Member Benefits available and the risks and uncertainty associated with continuing the lawsuit.

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4. Why is this lawsuit a class action?

   In a class action, one or more people (called class representatives) sue on behalf of all people who they allege have similar legal claims. Together, after a court grants certification, all these people are called a class or class members. One court resolves the issues for all class members, except for those class members who timely exclude themselves (opt-out) from the class.

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5. How do I know if I am included in the Settlement?

   You are included in the Settlement Class if you are a living individual in the United States whose Private Information was implicated in the Data Incident.

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

   Yes. Excluded from the Settlement Class are: (a) all persons who are directors and officers of Defendant; (b) governmental entities; and (c) the Judge assigned to the lawsuit, that Judge’s immediate family, and Court staff.

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7. What if I am still not sure whether I am part of the Settlement?

   If you are still not sure whether you are a Settlement Class Member, you may call toll-free 1-877-734-7165.

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8. What does this Settlement provide?

   If you are a Settlement Class Member, you can submit a Claim Form for the following Settlement Class Member Benefits:

   Cash Payment A – Documented Losses

   You may submit a Claim Form with reasonable documentation for losses related to the Data Incident for up to $5,000 per Settlement Class Member.

   Examples of expenses incurred as a result of the Data Incident, include (without limitation) bank fees, long distance phone charges, cell phone charges (only charged by the minute), data charges (only if charged based on the amount of data used), postage, gasoline for local travel and fees for credit reports, credit monitoring, or other identity theft insurance products purchased.

   Examples of reasonable documentation include (but are not limited to): telephone records, correspondence including emails, or receipts. Reasonable documentation must be generated or prepared by a third party or the Settlement Class Member supporting a request for expenses paid.

   Personal certifications, declarations, or affidavits from the Settlement Class Member do not constitute reasonable documentation but may be included to provide clarification, context, or support for other submitted reasonable documentation. You will not be reimbursed for expenses if you have been reimbursed for the same expenses by another source, including compensation provided in connection with the credit monitoring and identity theft protection product offered as part of the notification letter provided by the Defendant or otherwise.

   If you do not submit reasonable documentation supporting a loss, or if your Claim Form is invalid as determined by the Settlement Administrator, and you do not cure your Claim Form, your Claim Form will be treated as if you elected Cash Payment B – Alternate Cash.

   Cash Payment B – Alternate Cash

   Instead of selecting Cash Payment A, without providing documentation, you may submit a Claim Form to receive an alternative cash payment in the amount of $40.

   If the amount of timely and valid Claim Forms exceeds an aggregate amount of $1 million, your Cash Payment will be subject to a pro rata (a legal term meaning equal share) reduction.

   Credit Monitoring

   If you are a Settlement Class Member, you will automatically receive three years of free Credit Monitoring. The Credit Monitoring enrollment code is located on your Notice. You do not need to submit a Claim Form to receive free Credit Monitoring services.

   Activate your Credit Monitoring services here. If you currently have an active credit monitoring product, you may delay activation of the Credit Monitoring enrollment for up to 12 months.

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9. What am I giving up to receive Settlement Class Member Benefits or stay in the Settlement Class?

   Unless you exclude yourself (opt-out), you will remain in the Settlement Class. If the Settlement is approved and becomes final, all Court orders and any judgments will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against the Released Parties about the Released Claims in this lawsuit. The specific rights you are giving up are called “Released Claims.”

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10. What are the Released Claims?

    Section XI of the Settlement Agreement describes the Releases, Released Claims, and Released Parties, in necessary legal terminology, so please read this section carefully. The Settlement Agreement is available here. For questions regarding the Releases, Released Claims, or Released Parties and what the language in the Settlement Agreement means, you can also contact Class Counsel listed below for free, or you can talk to your own lawyer at your own expense.

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11. How do I submit a Claim Form?

    The deadline to file a claim for the Settlement was February 15, 2026.
    
    Requests for Claim Forms are no longer being accepted.

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12. What happens if my contact information changes after I submit a Claim Form?

    If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by writing to:

    Affiliated Dermatologists Data Incident
    Settlement Administrator
    PO Box 2684
    Portland, OR 97208-2684

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13. When will I receive my Settlement Class Member Benefits?

    If you filed a timely and valid Claim Form, your cash payment is scheduled to be issued at the end of May 2026.

    If you are a Settlement Class Member, you will automatically receive three years of free Credit Monitoring. The Credit Monitoring enrollment code is located on your Notice. You do not need to submit a Claim Form to receive free Credit Monitoring services.

    Activate your Credit Monitoring services here. If you currently have an active credit monitoring product, you may delay activation of the Credit Monitoring enrollment for up to 12 months.

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14. Where can I find my Credit Monitoring enrollment code?

    If you received an Email Notice, your 10-digit Credit Monitoring enrollment code can be found at the top of the Email.

    If you received a Postcard Notice, your 10-digit Credit Monitoring enrollment code can be found on the inside of your Postcard Notice.

    If you did not receive a Notice but believe you may be a Settlement Class Member or if you are having trouble locating your Credit Monitoring enrollment code, you may call toll-free 1- 877 734 7165, or write to the Settlement Administrator at:

    Affiliated Dermatologists Data Incident
    Settlement Administrator
    PO Box 2684
    Portland, OR 97208-2684

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15. How do I opt-out of the Settlement?

    The deadline to exclude yourself from the Settlement was January 31, 2026.

    Requests for Exclusion are no longer being accepted.

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16. If I opt-out can I still get anything from the Settlement?

    No. If you excluded yourself, you will not be able to receive Settlement Class Member Benefits, and you will not be bound by the Settlement or any judgments in this lawsuit. You can only get Settlement Class Member Benefits if you stay in the Settlement. You will only get a cash payment if you submit a timely and valid Claim Form. You do not need to submit a Claim Form to receive free Credit Monitoring.

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17. If I do not opt-out, can I sue the Defendant for the same thing later?

    No. Unless you excluded yourself, you give up any right to sue any of the Released Parties for the legal claims this Settlement resolves and Releases, and you will be bound by all the terms of the Settlement, proceedings, orders, and judgments in the lawsuit. You must opt-out of this lawsuit to start or continue your own lawsuit or be part of any other lawsuit against the Released Parties about the Released Claims in this Settlement. If you have a pending lawsuit, speak to your lawyer in that lawsuit immediately.

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18. How do I tell the Court I do not like the Settlement?

    The deadline to object to the Settlement was January 21, 2026.

    Objections are no longer being accepted.

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19. What is the difference between objecting and asking to be excluded?

    Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class. Opting-out is telling the Court that you do not want to be part of the Settlement Class. If you opt-out, you cannot object because you are no longer part of the Settlement.

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20. Do I have a lawyer in the lawsuit?

    Yes. The Court has appointed Andrew W. Ferich of Ahdoot & Wolfson, PC, Mariya Weekes of Milberg Coleman Bryson Phillips & Grossman PLLC, Kristen Lake Cardoso of Kopelowitz Ostrow P.A., and Marc H. Edelson of Edelson Lechtzin LLP as Class Counsel to represent you and the Settlement Class for the purposes of this Settlement. You may hire your own lawyer at your own cost if you want someone other than Class Counsel to represent you in this lawsuit.

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21. How will Class Counsel be paid?

    Class Counsel will file a motion asking the Court to award attorneys’ fees and costs of up to $815,000 to be paid by Defendant separate from Defendant’s obligation to pay Settlement Class Member Benefits. Class Counsel will also ask the Court to approve the Service Awards for the Class Representatives of up to $2,000 each for their efforts. If awarded by the Court, the attorneys’ fees and costs, and the Service Awards will be paid directly by Defendant. The Court may award less than these amounts.

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

    The Final Approval was held and approved on March 20, 2026, at 10:00 a.m. before the Honorable Vijayant Pawar at the Morris County Courthouse, 56 Washington Street, Morristown, NJ 07960.

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23. Do I have to attend the Final Approval 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 attend the Final Approval Hearing to speak about it. As long as you file your written objection by the deadline, the Court will consider it.

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24. May I speak at the Final Approval Hearing?

    If there are objections that were filed by the deadline, the Court will consider them. If you file a timely objection, and you (or your lawyer) ask to speak at the hearing, the Court may hear objections at the hearing.

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25. How do I get more information about the Settlement?

    This Notice summarizes the Settlement. Complete details about the Settlement are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available here. You may get additional information by calling toll-free 1- 877-734-7165, or by writing to:

    Affiliated Dermatologists Data Incident
    Settlement Administrator
    PO Box 2684
    Portland, OR 97208-2684

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PLEASE DO NOT TELEPHONE THE COURT OR THE COURT’S CLERK OFFICE REGARDING THIS SETTLEMENT.