Superior Court for Allen County, Indiana In re Fort Wayne Medical Education Program Data Incident Litigation Case No. 02D02-2510-CE-000038 NOTICE OF PROPOSED CLASS ACTION SETTLEMENT IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE DECEMBER 2024 FORT WAYNE MEDICAL EDUCATION PROGRAM DATA INCIDENT, A PROPOSED CLASS ACTION SETTLEMENT MAY AFFECT YOUR RIGHTS, AND ENTITLE YOU TO BENEFITS AND A CASH PAYMENT. A court has authorized this notice. This is not a solicitation from a lawyer. You are not being sued. Please read this Notice carefully and completely. • A Settlement has been reached with Fort Wayne Medical Education Program i/s/h/a Fort Wayne Medical Society Foundation, Inc. d/b/a Fort Wayne Medical Education Program (“FWMEP” or “Defendant”) in a class action lawsuit. This case is about the targeted cyberattack on FWMEP's computer systems that occurred in December 2024 (the “Data Incident”). Certain files that contained private information were accessed. These files may have contained personal information such as personally identifiable information (PII); protected health information (PHI). • The lawsuit is called In re Fort Wayne Medical Education Program Data Incident Litigation, Case No. 02D02-2510-CE-000038. It is pending in the Superior Court for Allen County, Indiana (the “Litigation”). • FWMEP denies that it did anything wrong, and the Court has not decided who is right. • The parties have agreed to settle the lawsuit (the “Settlement”) to avoid the costs and risks, disruptions, and uncertainties of continuing the Litigation. • FWMEP's records indicate that you are a Class Member, and entitled to benefits under the Settlement. You may have received a previous notice directly from FWMEP. • Your rights are affected whether you act or don’t act. Please read this Notice carefully and completely. In re Fort Wayne Medical Education Program Data Incident Litigation Page 1 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT DEADLINE SUBMIT A CLAIM The only way to receive benefits or payments from this Settlement October 27, 2026 is by submitting a valid and timely Claim Form. The fastest way to submit your Claim Form is online at www.FWMEPDataSettlement.com. If you prefer, you can download the Claim Form from the Settlement Website and mail it to the Settlement Administrator. You may also call or email the Settlement Administrator to receive a paper copy of the Claim Form. OPT OUT OF THE You can choose to opt out of the Settlement and receive no benefit October 27, 2026 SETTLEMENT or payment. This option allows you to sue, continue to sue, or be part of another lawsuit against the Defendant related to the legal claims resolved by this Settlement. You can hire your own lawyer at your own expense. OBJECT TO THE If you do not opt out of the Settlement, you may object to it by October 27, 2026 SETTLEMENT AND/OR writing to the Court about why you don’t like the Settlement. You may also ask the Court for permission to speak about your ATTEND A HEARING objection at the Final Approval Hearing. If you object, you may also file a claim for Settlement benefits. DO NOTHING Unless you opt out of the Settlement, you are automatically part of No Deadline the Settlement. If you do nothing, you will not receive benefits or payments from this Settlement and you will give up the right to sue, continue to sue, or be part of another lawsuit against the Defendant related to the legal claims resolved by this Settlement. • These rights and options—and the deadlines to exercise them—are explained in this Notice. • The Court in charge of this case still has to decide whether to approve the Settlement. In re Fort Wayne Medical Education Program Data Incident Litigation Page 2 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com WHAT THIS NOTICE CONTAINS BASIC INFORMATION .................................................................................................... 3 WHO IS IN THE SETTLEMENT .......................................................................................... 4 THE SETTLEMENT BENEFITS........................................................................................... 4 SUBMITTING A CLAIM FORM FOR SETTLEMENT BENEFITS ................................................ 6 THE LAWYERS REPRESENTING YOU ............................................................................... 6 EXCLUDING YOURSELF FROM THE SETTLEMENT ............................................................ 7 COMMENTING ON OR OBJECTING TO THE SETTLEMENT.................................................. 7 THE COURT’S FINAL APPROVAL HEARING ...................................................................... 8 IF I DO NOTHING ........................................................................................................... 9 GETTING MORE INFORMATION ...................................................................................... 9 Basic Information 1. Why was this Notice issued? The Superior Court for Allen County, Indiana, authorized this 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. This Notice explains the lawsuit, your legal rights, what benefits are available, and who can receive them. The lawsuit is called In re Fort Wayne Medical Education Program Data Incident Litigation, Case No. 02D02- 2510-CE-000038. It is pending in the Superior Court for Allen County, Indiana. The people that filed this lawsuit are called the “Plaintiffs” (or “Class Representatives”) and the company they sued, Fort Wayne Medical Education Program i/s/h/a Fort Wayne Medical Society Foundation, Inc. d/b/a Fort Wayne Medical Education Program, is called the “Defendant.” 2. What is this lawsuit about? This lawsuit alleges that during the December 2024 targeted cyberattack on FWMEP's computer systems, certain files that contained private information were accessed. These files may have contained personal information such as personally identifiable information (PII); protected health information (PHI). 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 are Stacey Alexander; Brittney Hill; Nikol Christlieb; Laura Bell; Jason Smead; Brandy Smith; and Randy Zerler. Everyone included in this Action are the Class Members. In re Fort Wayne Medical Education Program Data Incident Litigation Page 3 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com 4. Why is there a Settlement? The Court did not decide whether the Plaintiffs or the Defendant are 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. The Plaintiffs and their attorney think the Settlement is best for all Class Members. Who is in the Settlement? 5. Who is included in the Settlement? The court has defined the Class this way: “All Persons whose Private Information was potentially compromised as a result of the Incident and included on the Settlement Class List.” 6. Are there exceptions to being included? Yes. Excluded from the Class are: (i) the Judge assigned to evaluate the fairness of this Settlement, Court personnel and any members of their immediate families; (ii) FWMEP, and any entity in which FWMEP has a controlling interest, is a parent or subsidiary, or which is controlled by FWMEP, and the affiliates, legal representatives, attorneys, heirs, predecessors, successors and assigns of FWMEP; and (iii) any other person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the criminal activity occurrence of the Incident or who pleads nolo contendere to any such charge. 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: • Email: info@FWMEPDataSettlement.com • Call toll free, 24/7: (833) 296-0908 • By mail: FWMEP Data Incident Settlement c/o Settlement Administrator P.O. Box 25226 Santa Ana, CA 92799-9958 You may also view the Settlement Agreement at www.FWMEPDataSettlement.com. The Settlement Benefits 7. What does the Settlement provide? FWMEP has agreed to pay for a number of Class benefits, which are explained below. All Class Members are eligible to claim either Credit Monitoring Services or Medical Monitoring Services, and/or one or more cash payments. CREDIT MONITORING SERVICES or MEDICAL MONITORING SERVICES All Class Members are eligible to claim either Credit Monitoring Services or Medical Monitoring Services. Your specific eligibility will depend on whether your Social Security number may have been compromised in the Data Incident. 1. If it was, you are part of Group 1, and eligible to claim Credit Monitoring Services. If it was not, you are part of Group 2, and eligible to claim Medical Monitoring Services. FWMEP has provided this In re Fort Wayne Medical Education Program Data Incident Litigation Page 4 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com information to the Settlement Administrator, and you will receive the appropriate service if you file a valid claim. Credit Monitoring Services. All Group 1 Class Members are eligible to claim two years of CyEx Financial Shield Complete. This comprehensive service comes with $1 million of financial fraud insurance, and includes monitoring for: • fraud or identity theft • unauthorized financial transactions • personal information associated with high-risk transactions If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems. 2. Medical Monitoring Services. All Group 2 Class Members are eligible to claim two years of CyEx Medical Shield Complete. This comprehensive service comes with $1 million of medical identity theft insurance, and includes monitoring for: • healthcare insurance ID exposure • Medical Record Number (MRN) exposure • unauthorized Health Savings Account (HSA) spending If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems. If you have questions about whether your Social Security number may have been compromised in the Data Incident, and whether you are part of Group 1 or Group 2, you can contact the Settlement Administrator any time at: • Email: info@FWMEPDataSettlement.com • Call toll free, 24/7: (833) 296-0908 • By mail: FWMEP Data Incident Settlement c/o Settlement Administrator P.O. Box 25226 Santa Ana, CA 92799-9958 CASH PAYMENTS Reimbursement for Ordinary Out-of-Pocket Losses. If you incurred actual, documented out-of- pocket expenses due to the Data Incident, you can get back up to $500.00. The losses must have occurred between December 12, 2024, and October 27, 2026. This benefit covers out-of-pocket expenses like: • fees for credit reports, credit monitoring, or freezing and unfreezing your credit • cost to replace your IDs • postage to contact banks by mail You need to send proof, like receipts, to show how much you spent or lost. You can also send notes or papers you made yourself to explain or support other proof, but those notes or papers alone are not enough to make a valid claim. Your proof or notes should show that your expenses were because of the Data Incident. You cannot claim a payment for expenses that have already been reimbursed by a third party. In re Fort Wayne Medical Education Program Data Incident Litigation Page 5 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com Reimbursement for Extraordinary Out-of-Pocket Losses. If you lost money because of identity theft or fraud, you can get back up to $5,000.00. You will need to show that: • the theft or fraud was probably caused by the Data Incident • the losses are not already covered by Out-of-Pocket Expenses • you tried to prevent the loss or get your money back, such as by using insurance you already have The losses must have occurred between December 12, 2024, and October 27, 2026. You need to send proof, like receipts, to show how much you spent or lost. You can also send notes or papers you made yourself to explain or support other proof, but those notes or papers alone are not enough to make a valid claim. Your proof or notes should show that your expenses were because of the Data Incident. Reimbursement for Lost Time. Class Members who spent time responding to the Data Incident may claim up to four hours, at $20.00 per hour, for a maximum of $80.00. You must have spent the time on tasks related to the Data Incident. Some examples include things like: • changing your passwords • investigating suspicious activity in your accounts • researching the Data Incident You must briefly describe how you spent this time, including how much time you spent on each task you claim. The amount you claim for Lost Time will count toward the $500.00 Ordinary Out-of-Pocket Losses cap. Alternative Cash Payment. Instead of any other payments or benefits, you may claim a one-time $40.00 cash payment. You do not have to provide any proof or explanation to claim this payment. If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at: • Email: info@FWMEPDataSettlement.com • Call toll free, 24/7: (833) 296-0908 • By mail: FWMEP Data Incident Settlement c/o Settlement Administrator P.O. Box 25226 Santa Ana, CA 92799-9958 8. What claims am I releasing if I stay in the Class? If you stay in the class, you won’t be able to be part of any other lawsuit against FWMEP about the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section RELEASE) describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available at www.FWMEPDataSettlement.com. In re Fort Wayne Medical Education Program Data Incident Litigation Page 6 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com 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 at www.FWMEPDataSettlement.com. If you prefer, you can download a printable Claim Form from the website and mail it to the Settlement Administrator at: FWMEP Data Incident Settlement c/o Settlement Administrator P.O. Box 25226 Santa Ana, CA 92799-9958 You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (833) 296-0908, by email info@FWMEPDataSettlement.com, or by U.S. mail at the address above. 10. Are there any important Settlement payment deadlines? If you are submitting a Claim Form online, you must do so by October 27, 2026. If you are submitting a claim by U.S. mail, the completed and signed Claim Form, including supporting documentation, must be postmarked no later than October 27, 2026. 11. When will the Settlement benefits be issued? The Court will hold a final approval hearing on December 7, 2026 (see Question 18). 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 payments will be distributed if the Court grants final approval, and after any appeals are resolved. The Lawyers Representing You 12. Do I have a lawyer in the case? Yes, the Court has appointed attorney Lynn Toops of CohenMalad, LLP, to represent you and other Class Members (“Class Counsel”). 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. 14. How will Class Counsel be paid? Class Counsel will ask the court to approve $475,000.00 as reasonable attorney's fees and reimbursement of litigation costs. This amount will be paid by FWMEP. Class Counsel will also ask for Service Award Payment payments of $2,500.00 for each of the Class Representatives. Service Award Payment payments will also be paid by FWMEP. Excluding Yourself from the Settlement In re Fort Wayne Medical Education Program Data Incident Litigation Page 7 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com 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 Settlement benefits or payment. However, you will keep any rights you may have to sue FWMEP 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 October 27, 2026. To be valid, your Request for Exclusion must have the following information: (1) the name of the Litigation: In re Fort Wayne Medical Education Program Data Incident Litigation, Case No. 02D02-2510-CE-000038, pending in the Superior Court for Allen County, Indiana; (2) your full name, mailing address, telephone number, and email 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: FWMEP Data Incident Settlement ATTN: Exclusion Request P.O. Box 25226 Santa Ana, CA 92799-9958 Your Request for Exclusion must be submitted, postmarked, or emailed by October 27, 2026. 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 a Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons for why you think the Court should not approve the Settlement. The Court will consider your views. You cannot object if you have excluded yourself from the Settlement (see Question 15) You must provide the following information for the Court to consider your objection: (a) the name of the proceedings; (b) the Settlement Class Member’s full name, address, telephone number (if any), and email address (if any); In re Fort Wayne Medical Education Program Data Incident Litigation Page 8 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com (c) information identifying the objector as a Settlement Class Member; (d) a written statement of all grounds for the objection, accompanied by any legal support or documentation the objector cares to submit; (e) a statement as to whether the objection applies only to the objector, to a specific subset of the class, or to the entire class; (f) the identity of all lawyers (if any) representing the objector; (g) a statement of whether the objector or his/her attorneys intends to appear at the Final Fairness Hearing; (h) a list of all persons who will be called to testify at the Final Fairness Hearing in support of the objection; (i) a list of all other matters in which the objecting Settlement Class Member and/or his/her attorney has lodged an objection to a class action settlement; and (j) the objector’s signature For your objection to be valid, it must meet each of these requirements. To be considered by the Court, you must file your complete objection with the Clerk of Court by October 27, 2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and counsel for Defendants. Clerk of the Court Settlement Administrator Clerk of the Court FWMEP Data Incident Settlement 715 S. Calhoun Street ATTN: Objections Fort Wayne, IN 46802 P.O. Box 25226 Santa Ana, CA 92799-9958 Class Counsel Counsel for Defendants Lynn Toops Janet Thompson COHENMALAD, LLP GORDON REES SCULLY MANSUKHANI, LLP 1 Indiana Square, Suite 1400 1 Indiana Square, Suite 1400 Indianapolis, IN 46204 Indianapolis, IN 46204 Joseph Salvo John Mills GORDON REES SCULLY MANSUKHANI, LLP 1 Battery Park Plaza, 28th Floor New York, NY 10004 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. In re Fort Wayne Medical Education Program Data Incident Litigation Page 9 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com The Court’s Final Approval Hearing 18. When is the Court’s Final Approval Hearing? The Court will hold a final approval on December 7, 2026 at 10:00 a.m. Eastern Time, in Room 316 of the Superior Court for Allen County, Indiana, at 715 S. Calhoun Street, Fort Wayne, IN 46802. 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 Service Award Payment payments to the Class Representatives. 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 date and time of this hearing may change without further notice. Please check www.FWMEPDataSettlement.com for updates. 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 wish, 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 filed on time. You may also pay your own lawyer to attend, but you do not have to. 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. Getting More Information 21. How do I get more information? This Notice is a summary of the proposed Settlement. The full Settlement Agreement and other related documents are available at the Settlement Website, www.FWMEPDataSettlement.com. If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at: • Email: info@FWMEPDataSettlement.com • Call toll free, 24/7: (833) 296-0908 • By mail: FWMEP Data Incident Settlement c/o Settlement Administrator P.O. Box 25226 Santa Ana, CA 92799-9958 In re Fort Wayne Medical Education Program Data Incident Litigation Page 10 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 715 S. Calhoun Street, Fort Wayne, IN 46802. DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT In re Fort Wayne Medical Education Program Data Incident Litigation Page 11 of 11 «2DBarcode» SIMID: «SIMID» | CaseID: 9644 Questions? Call (833) 296-0908 Toll-Free or Visit www.FWMEPDataSettlement.com