Frequently Asked Questions

Basic Information

1. Why was the Notice issued?

The Circuit Court of Bibb County, Alabama, authorized the Notice. You have a right to know about the proposed Settlement of this class action lawsuit, and about all of your options, before the Court decides whether to grant final approval of the Settlement. The Notice explains the lawsuit, your legal rights, what benefits are available, and who can receive them.

The lawsuit is captioned Kornegay et al. v. Heart South Cardiovascular Group, P.C., Case No. 07-CV-2024-900089.00, pending in the Circuit Court of Bibb County, Alabama. The people that filed this lawsuit are called the “Plaintiffs” (or “Class Representatives”) and the entity they sued, HSCG, is called the “Defendant.”

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2. What is this lawsuit about?

This class action lawsuit is about the targeted cyberattack on HSCG's computer systems that occurred in May 2024 (the “Data Incident”). Certain files containing sensitive information were accessed. This sensitive information may have included names, addresses, dates of birth, driver’s license numbers, Social Security numbers, diagnoses, conditions, lab results, medications, and other treatment information.

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3. What is a class action?

In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are called the “Plaintiffs” or “Class Representatives.” Together, the people included in the class action are called a “Class” or “Class Members.” One court resolves the lawsuit for all Class Members, except for those who opt out from the settlement. In this Settlement, the Class Representatives Dana Kornegay, Megan Moore, Roland Johnson, John Kopp, and Jennifer Craft, and everyone included in this Action are the Class Members.

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4. Why is there a settlement?

The Court did not decide whether the Plaintiffs or the Defendant is right. Both sides have agreed to a Settlement to avoid the costs and risks of a trial, and to allow the Class Members to receive benefits from the Settlement. Plaintiffs and their attorneys think the Settlement is best for all Class Members.

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Who is in the Settlement

5. Who is included in the Settlement?

The court has defined the Class this way: “all individuals residing in the United States who, following Defendant’s investigation of the Data Incident, were sent notification by Defendant that their Personal Information was or may have been compromised in the Data Incident.”

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6. Are there exceptions to being included?

Yes. Excluded from the Class are: (1) the Judge in this case, and the Judge’s family and staff; (2) HSCG and related companies and corporate directors; and (3) anyone who timely removes themselves from the Settlement.

If you are not sure whether you are a Class Member, you can ask for free help any time by contacting the Settlement Administrator at:

HSCG Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 360-6883
info@HeartSouthSettlement.com

You may also view the Settlement Agreement here.

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The Settlement Benefits

7. What does the Settlement provide?

HSCG has agreed to establish a $500,000.00 Settlement Fund. Part of the Settlement Fund will be used to pay for expenses like attorneys' fees and costs, the Service Award to the Plaintiffs, and the costs of administering the Settlement. All the rest of the Settlement Fund will be used to pay benefits that Class Members can claim. You are not limited to one benefit, and can claim one or all of them.

Pro Rata Cash Payment: All Class Members may submit a claim for a pro rata cash payment. After all expenses and other claims have been paid out, the money remaining in the Settlement Fund will be equally divided among everyone who claimed a pro rata cash payment. Class Counsel expects that these payments will be approximately $50.00 per valid claim.

Reimbursement for Out-of-Pocket Losses: If the Data Incident caused you real, documented losses, you may file a claim for reimbursement. These expenses must have happened on after May 29, 2024, and must be unreimbursed. You can get back up to $5,000.00.

This benefit covers out-of-pocket expenses like:

  1. losses relating to fraud, identity theft, falsified tax returns, or other ways your information was misused

  2. costs associated with freezing or unfreezing your credit report with any credit reporting agency

  3. buying or extending credit monitoring services

  4. miscellaneous expenses such as notary, fax, postage, copying, mileage, and long-distance telephone charges

You must send proof, like receipts, to establish a valid claim. You can add your own notes to explain other papers, but those notes alone are not enough to make a valid claim.

Credit Monitoring. All Class Members are eligible to receive two years of Medical Shield Complete. These services include:

  1. credit monitoring

  2. dark web monitoring

  3. real-time inquiry alerts

  4. $1 million in identity theft insurance

If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at:

HSCG Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 360-6883
info@HeartSouthSettlement.com

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8. What claims am I releasing if I stay in the Class?

Unless you opt out of the Settlement, you won’t be able to sue, continue to sue, or be part of any other lawsuit against the Defendants about any of the legal claims this Settlement resolves. The “Releases” section of the Settlement Agreement (Section XII) describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available here.

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Submitting a Claim Form for a Settlement Payment

9. How do I submit a claim for a Settlement benefit?

The fastest way to submit your Claim Form is online here. If you prefer, you can download a printable Claim Form here and mail it to the Settlement Administrator at:

HSCG Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free,

(833) 360-6883, by email info@HeartSouthSettlement.com, or by U.S. mail at the address above.

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10. Are there any important Settlement payment deadlines?

If you are filing online, complete your claim by October 9, 2025. If you are filing a paper copy, your signed Claim Form along with any necessary documentation must be postmarked by October 9, 2025.

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11. When will the Settlement benefits be issued?

The Court will hold a final hearing at a date to be determined. Please check the Important Dates page for updates. If the Court approves the Settlement, there may be appeals. We do not know if appeals will be filed, or how long it will take to resolve them if they are filed.

Settlement benefits will be distributed if the Court grants final approval, and after any appeals are resolved.

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The Lawyers Representing You

12. Do I have a lawyer in the case?

Yes, the Court appointed attorneys Jon Mann of Pittman, Dutton, Hellums, Bradley & Mann, PC; Mariya Weekes of Milberg Coleman Bryson Phillips Grossman, PLLC; and Raina C. Borrelli of Strauss Borrelli PLLC, to represent you and other Class Members (“Class Counsel”).

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13. Should I get my own lawyer?

You will not be charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense.

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14. How will Class Counsel be paid?

Class Counsel will ask the court to approve attorneys’ fees and costs up to $186,666.66. Class Counsel will also ask for a Service Award of $4,000.00 for the Class Representative. Theses expenses along with the cost of administration will be paid from the Settlement Fund.

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Excluding Yourself from the Settlement

15. How do I opt out of the Settlement?

If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement. This is called a Request for Exclusion, and is sometimes also called “opting out.” If you opt out, you will not receive a Settlement payment, but you will keep any rights you may have to sue HSCG on your own about the legal issues in this case.

If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You will not be eligible to receive any Settlement benefits if you exclude yourself.

The deadline to exclude yourself from the Settlement is September 9, 2025.

To be valid, your Request for Exclusion must have the following information:

  1. the name of the Action: Kornegay et al. v. Heart South Cardiovascular Group, P.C., Case No. 07-CV-2024-900089.00, pending in the Circuit Court of Bibb County, Alabama;

  2. your full name and current mailing address;

  3. personal signature; and

  4. the words “Request for Exclusion” or a clear and similar statement that you do not want to participate in the Settlement.

You may only exclude yourself, not any other person.

Mail your Request for Exclusion to the Settlement Administrator at:

HSCG Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

Your Request for Exclusion must be postmarked by September 9, 2025.

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Commenting on or Objecting to the Settlement

16. How do I tell the Court if I like or do not like the Settlement?

If you are in the Class and do not like the Settlement, you can object. That means telling the Court why you think it should not be approved. The Court will consider what you say.

You cannot object if you have excluded yourself from the Settlement (see Question 15)

To be valid, your objection must provide the following information:

  1. the name of the Action: Kornegay et al. v. Heart South Cardiovascular Group, P.C., Case No. 07-CV-2024-900089.00, pending in the Circuit Court of Bibb County, Alabama;

  2. your full name, current mailing address, and telephone number;

  3. a clear description of all the reasons you object; include any legal support you may have for your objection and explain if your objection applies only to you or the entire Class;

  4. if you have hired your own lawyer to represent you at the Final Approval Hearing, provide their name and telephone number;

  5. whether or not you or your lawyer would like to speak at the Final Approval Hearing;

  6. if you have objected in other cases, list those cases;

  7. your signature (or, if you have hired your own lawyer, your lawyer’s signature).

For your objection to be valid, it must meet each of these requirements.

You must file your complete objection with the Clerk of Court by September 9, 2025. You must also send copies of the objection to both Class Counsel and counsel for Defendant.

Clerk of the Court

Class Counsel

Counsel for Defendants

Circuit Court of Bibb County, Alabama
35 Court Square East
Centreville, AL 35042




Jonathan S. Mann
PITTMAN, DUTTON, HELLUMS,
BRADLEY & MANN, P.C.

2001 Park Place North, Suite 1100
Birmingham, AL 35203
Tel: (205) 322-8880
Email: jonm@pittmandutton.com

Jill H. Fertel
Cipriani & Werner P.C.
3155 North Point Parkway, Suite G-100
Alpharetta, GA 30005



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17. What is the difference between objecting and excluding?

Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement is opting out and stating to the Court that you do not want to be part of the Settlement. If you opt out of the Settlement, you cannot object to it because the Settlement no longer affects you.

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The Court’s Final Approval Hearing

18. When is the Court’s Final Approval Hearing?

The Court will hold a hearing in this case to consider whether to approve the Settlement. The hearing will be at the Bibb County Courthouse, 35 Court Square East, Centreville, AL 35042, at a date to be determined.

At the final approval hearing, the Court will decide whether to approve the Settlement. The court will also decide how Class Counsel should be paid, and whether to award a Service Award to the Class Representative who brought this Action on behalf of the Class. The Court will also consider any objections to the Settlement.

If you are a Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see Question 16).

The hearing date and time may change without further notice. Please check the Important Dates page for updates.

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19. Do I have to come to the Final Approval Hearing?

No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you want to, but you do not have to.

If you file an objection, you do not have to come to the Final Approval Hearing to talk about it; the Court will consider it as long as it was complete and filed on time. You may also pay your own lawyer to attend, but you do not have to.

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If I Do Nothing

20. What happens if I do nothing at all?

If you do nothing, you will not receive a benefit from this Settlement. You will also give up the rights described in Question 8.

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Getting More Information

21. How do I get more information?

This website and the Notice are a summary of the proposed Settlement. The full Settlement Agreement and other related documents are available at the Important Documents page.

If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at:

HSCG Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 360-6883
info@HeartSouthSettlement.com

You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, Circuit Court of Bibb County, Alabama, 35 Court Square East, Centreville, AL 35042..

Do not contact the Court or Clerk of Court regarding this Settlement.

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