NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
In the Circuit Court of the 11th Judicial Circuit in and for Miami-Dade County, Florida
Jefferson, et al. v. Community Connections, Inc.
Case No. 2026-009556-CA-01
A court has authorized this Notice. This is not a solicitation from a lawyer.
If you were notified of Data Incidents that occurred at Community Connections, Inc. on or around October
2024 and April 2026, you may be entitled to Settlement Benefits from a class action settlement.
• A Settlement has been proposed in a class action lawsuit against Community Connections, Inc. (“Defendant”)
relating to the incident discovered on October 21, 2024 (the “2024 Data Incident”). Defendant determined
that certain files may have been accessed without authorization and, on or around August 22, 2025, sent out
notices to potentially impacted individuals. On April 4, 2026, Defendant experienced a second data security
incident by a different threat actor (the “2026 Data Incident,” collectively, with the 2024 Data Incident, the
“Data Incidents”). The Action alleges that Defendant was negligent or otherwise responsible for failing to
prevent the Data Incidents from occurring. Defendant denies all allegations. The Parties have reached a
Settlement to resolve the claims brought in the Action and to provide relief to Settlement Class Members.
• If you received a notice from Defendant that your Private Information may have been impacted as a result of
the Data Incidents, you are included in this Settlement as a “Class Member.”
• Under the Settlement, Defendant has agreed to pay, or cause to be paid, for the following: (a) all Settlement
Administration Costs; (b) Cash Payments A, B, and C to Settlement Class Members who submit a Valid
Claim; (c) Credit Monitoring for all Settlement Class Members, without requiring the submission of a Claim
Form; and (d) any Court-awarded attorneys’ fees, costs, and Service Awards.
This Notice may affect your rights. Please read it carefully.
Your Legal Rights and Options Deadline
You will receive a credit monitoring enrollment code, but you
will not receive a cash payment. You will remain a member of
DO NOTHING the Settlement Class, be bound by the Settlement if it is No Deadline
approved by the Court, and give up the right to sue Defendant
over the claims resolved by the Settlement.
SUBMIT A The only way to receive a cash payment. Claims must be October 6, 2026
CLAIM FORM submitted by October 6, 2026.
If you ask to be excluded, you will not be able to enroll in credit
monitoring or receive a cash payment, but you may be able to
EXCLUDE file your own lawsuit against Defendant, for the same claims.
This is the only option that leaves you the potential to file your September 21, 2026
YOURSELF
own lawsuit against Defendant for the claims that are being
resolved by the Settlement. To be effective, you must submit a
request for exclusion by the deadline.
If you do not exclude yourself from the Settlement Class, you
may submit an objection telling the Court why you do not like
OBJECT September 21, 2026
the Settlement. If your objection is overruled, you will be
bound by the Settlement.
These rights and options—and the deadlines to exercise them—are explained in this Notice. The Court in
charge of this case must still decide whether to approve the Settlement and the requested attorneys’ fees and
costs, service awards and administration costs. No Settlement benefits or payments will be provided unless and
until the Court approves the Settlement and it becomes final.
1
BASIC INFORMATION
1. Why is this Notice being provided?
A court authorized this Notice because you have the right to know about the proposed Settlement of this class
action lawsuit and about all of your rights and options before the Court decides whether to grant final approval
of the Settlement. This Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available,
who is eligible for the benefits, and how to get them.
The case is known as Jefferson, et al. v. Community Connections, Inc., Case No. 2026-009556-CA-01 currently
pending in the 11th Judicial Circuit in and for Miami-Dade County, Florida (the “Action”). The people who
filed this lawsuit are referred to as the “Plaintiffs” or “Class Representatives,” and the entity sued is referred to
as “Defendant.”
2. What is this lawsuit about?
The lawsuit arises from the Data Incidents. On or around October 2024 and April 2026, Defendant discovered
that unauthorized third parties potentially gained access to their computer systems. Plaintiffs allege that
Defendant did not adequately protect Private Information and assert claims including negligence, breach of
implied contract, and unjust enrichment.
Defendant denies any wrongdoing, and no court or other entity has made any judgment or other determination
of any wrongdoing or that any law has been violated. Defendant denies all other claims made in the Action. By
entering into the Settlement, Defendant is not admitting any wrongdoing.
3. Why is the lawsuit a class action?
In a class action, the Class Representatives sue on behalf of all people who are alleged to have similar claims.
Together, in the context of a settlement like this one, all these people are called a Settlement Class or Settlement
Class Members. One court resolves the issues for all Settlement Class Members, except for those Settlement
Class Members who timely opt out of the Settlement Class.
4. Why is there a Settlement?
Plaintiffs and Defendant do not agree about the claims made in this Action. The Action did not go to trial, and
the Court did not decide in Plaintiffs’ or Defendant’s favor. Instead, Plaintiffs and Defendant agreed to settle
the Action. Plaintiffs and the attorneys for the Settlement Class (“Class Counsel”) believe the Settlement is best
for all Settlement Class Members because of the Settlement benefits made available under the Settlement, the
risks and uncertainty associated with continued Action, and the nature of the defenses raised by Defendant.
WHO IS INCLUDED IN THE SETTLEMENT?
5. How do I know if I am part of the Settlement?
You are a Settlement Class Member if your Private Information was impacted as a result of the Data Incidents,
including all individuals who were sent a Notice Letter. If you are not sure whether you are a Settlement Class
Member, you may contact the Settlement Administrator at 1-888-506-1361 or email
[email protected].
2
6. Are there exceptions to being included in the Settlement?
Yes. Excluded from the Settlement Class are (a) Defendant and its officers and directors, and (b) any Judge to
whom this case is assigned as well as their judicial staff and immediate family members and any individual who
timely and validly opts out of the Settlement.
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 go to the Settlement Website at
www.CCDataSettlement.com or call the Settlement Administrator’s toll-free number at 1-888-506-1361 or
email [email protected].
THE SETTLEMENT BENEFITS—WHAT YOU GET IF YOU QUALIFY
8. What does the Settlement provide?
Settlement Class Member Benefits means the Cash Payments and Credit Monitoring that Settlement Class
Members may elect in the Settlement.
All Settlement Class Members must submit a Valid Claim to the Settlement Administrator to receive a Cash
Payment payable from or on behalf of Defendant. If a Settlement Class Member does not submit a Valid Claim,
the Settlement Class Member will release his or her claims without receiving a Cash Payment, but they will
receive a Credit Monitoring enrollment code.
Cash Payment A – Documented Losses. All Settlement Class Members are eligible to submit a claim for up
to $5,000.00 per Settlement Class Member upon presentment of reasonable documentation of losses related to
fraud and/or identity theft as a result of the Data Incidents. Documented Losses include, by way of example,
unreimbursed losses relating to fraud or identity theft: if (i) the loss is an actual, documented, and unreimbursed
monetary loss; (ii) the loss was more likely than not caused by the Data Incidents; and (iii) the loss was incurred
after the date of the Data Incidents. To receive payment for documented losses, a Settlement Class Member
must complete and submit a Claim Form and include third-party documentation in support of the Claim. Claims
must be for actual, out-of-pocket monetary losses documented by receipts, invoices, or similar third-party
records. Except as expressly provided herein, personal certifications, declarations, or affidavits from the
Settlement Class Member alone do not constitute proper documentation, but may be included to provide
clarification, context, or support for other submitted reasonable documentation. Settlement Class Members shall
not be reimbursed for expenses if they have been reimbursed for the same expenses by another source, including
compensation provided in connection with any credit monitoring and identity theft protection product. If a
Settlement Class Member does not submit documentation supporting a loss, or if the Settlement Administrator
rejects for any reason the Settlement Class Member’s Claim and the Settlement Class Member fails to cure the
Claim, the Claim will be rejected. If a Settlement Class Member does not submit reasonable documentation
supporting a loss, or if their Claim is rejected by the Settlement Administrator for any reason, and the Settlement
Class Member fails to cure his or her Claim, the Claim will be rejected and the Settlement Class Member’s
Claim will be as if he or she elected Cash Payment C, provided the Claim was otherwise timely submitted.
Cash Payment B – Lost Time. Settlement Class Members may submit a Claim for reimbursement for time
spent remedying issues related to the Data Incidents or researching the Data Incidents at a rate of $25.00 per
hour, for up to four (4) hours (a total of $100.00), which shall require the Settlement Class Member to attest
the validity of the Class Member’s Lost Time Claim and to briefly describe the time spent. Settlement Class
Members may elect to submit a Claim for both Cash Payment A and Cash Payment B.
3
Cash Payment C – Alternative Cash Payment. As an alternative to Cash Payment A and Cash Payment B,
all Settlement Class Members may elect to receive Cash Payment C, which is a cash payment in the amount of
$50.00. No documentation is required to claim this benefit other than submission of a Valid Claim. Claims for
Cash Payment C are subject to an aggregate cap of $250,000.00. In the event the number of claims for an
Alternative Cash Payment exceeds the sum of $250,000.00, such claims will be reduced on a pro rata basis.
Credit Monitoring. In addition to a Cash Payment, all Settlement Class Members will be sent a code to enroll
in two (2) years of CyEx Medical Shield Complete with one (1) credit bureau credit monitoring. Settlement
Class Members do not need to submit a Claim but must activate the code sent to them in the Postcard Notice.
Further details regarding the automatic enrollment will be available on the Settlement Website.
Remedial Measures. Prior to Final Approval, Defendant will provide Class Counsel with a written and signed
confidential declaration regarding the data security measures, including the cost associated therewith, it
implemented following the Data Incidents to better protect the Settlement Class’s Private Information. The
costs of any such security measures on the part of Defendant were paid or will be paid separately by or on
behalf of Defendant.
HOW TO GET BENEFITS FROM THE SETTLEMENT
9. Do I need to submit a claim?
If you would like to receive Cash Payments benefits under the Settlement, you must submit a Claim Form. If
you do not want to give up your right to sue Defendant about the Data Incidents or the issues raised in this case,
you must exclude yourself, or opt out, from the Settlement Class. See Question 17 below for instructions on
how to exclude yourself. If you wish to object to the Settlement, you must (a) remain a Settlement Class Member
(i.e., you may not exclude yourself from the Settlement Class by opting out and also object to the Settlement)
and (b) submit a written objection. See Question 20 below for instructions on how to submit an objection.
10. How do I submit a claim?
You must submit a valid and timely Claim Form to the Settlement Administrator by October 6, 2026. You will
need your name, address, telephone number, and email address (if applicable) and unique ID and Passcode
provided in the Notice sent to you, to file a Claim Form.
Claim Forms can be submitted by mail or online at www.CCDataSettlement.com. If by mail, the Claim Form
must be postmarked by October 6, 2026. You may request that a Claim Form be mailed to you by calling 1-888-
506-1361 or by writing to:
Community Connections Data Incidents
PO Box 19504
Irvine, CA 92623
[email protected]
11. What am I giving up so as to receive Settlement Benefits or to stay in the Settlement Class?
Unless you timely submit an opt-out request to exclude yourself, you are choosing to remain in the Settlement
Class. If the Settlement is approved and becomes final, all Court orders will apply to you and legally bind you.
You will not be able to sue or be part of any other lawsuit against Defendant and Released Parties about the
legal issues in the Action that are released by this Settlement. The specific rights you are giving up are called
“Released Claims.”
4
12. What are the Released Claims?
The Settlement Agreement in Section XI describes the Release, in necessary legal terminology, so please read
this section carefully. The Settlement Agreement is available at www.CCDataSettlement.com, in the public
Court records on file in this Lawsuit. You can also request a copy of the Settlement Agreement be mailed to you
by calling or writing to the Settlement Administrator. For questions regarding the Releases or Released Claims
and what the language in the Settlement Agreement means, you can also contact one of the lawyers listed in
Question 15 for free, or you can talk to your own lawyer at your own expense.
13. What happens if my contact information changes after I submit a claim or receive the Notice?
If you change your mailing address or email address after you submit a Claim Form or after you received the
Notice, 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:
Community Connections Data Incidents
PO Box 19504
Irvine, CA 92623
[email protected]
14. When will I receive my Settlement Benefits?
If you file a timely and valid Claim Form, payment will be provided by the Settlement Administrator after the
Settlement is approved by the Court and becomes final.
It may take time for the Settlement to be approved and become final. Please be patient and check
the Settlement Website at www.CCDataSettlement.com, email [email protected] or contact
the attorneys in Question 15, below, for updates.
THE LAWYERS REPRESENTING YOU
15. Do I have a lawyer in this case?
The Court has appointed Scott Edelsberg of Edelsberg Law, P.A., and Tonyia Johnson of Shamis & Gentile
P.A. 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 and expense if you want someone other than Class Counsel to represent
you in the Action.
16. How will Class Counsel be paid?
Class Counsel will file a motion asking the Court for an award of attorneys’ fees and costs of $362,500.00.
They will also ask the Court to approve a service award in the amount of $2,500.00 to each of the three named
Plaintiffs. If awarded by the Court, attorneys’ fees and costs and the service awards will be paid by or on behalf
of Defendant. The Court may award less than these amounts.
A copy of Class Counsel’s motion for attorneys’ fees and costs, and service awards will be made available on the
Settlement Website at www.CCDataSettlement.com before the deadline for submission of objections. You may
also request a copy be mailed to you by calling the Settlement Administrator.
5
OPTING OUT OF THE SETTLEMENT
If you are a Settlement Class Member and want to keep any right you may have to sue or continue to sue
Defendant on your own based on the claims raised in the Action or released by the Released Claims, then you
must take steps to get out of the Settlement. This is called excluding yourself from, or opting out of, the
Settlement.
17. How do I get out of the Settlement?
The opt-out request must be personally signed by the Settlement Class Member and contain the name, address,
telephone number, and email address (if any), and include a statement indicating a request to be excluded from
the Settlement Class in Jefferson, et al. v. Community Connections, Inc., Case No. 2026-009556-CA-01. The
opt-out request must be postmarked and sent to the Settlement Administrator at the following address by
September 21, 2026:
Community Connections Data Incidents
Attn: Opt-outs
PO Box 19504
Irvine, CA 92623
18. If I opt-out, can I get anything from the Settlement?
No. If you opt out, you are telling the Court you do not want to be part of the Settlement. You can only
get Settlement benefits if you stay in the Settlement. If you opt out, do not submit a Claim Form.
19. If I do not opt-out, can I sue the Defendant for the same thing later?
No. Unless you opt out, you give up any right to sue Defendant and Released Parties for the claims this
Settlement resolves and releases relating to the Data Incidents. You must opt out of the Action to start your own
lawsuit against the Defendant or any of the Released Parties. If you have a pending lawsuit, speak to your lawyer
in that case immediately.
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 and do not exclude yourself, you may object to the Settlement by mailing
a written objection no later than September 21, 2026.
For an objection to be considered by the Court, the objection must state:
a. the objector’s full name, mailing address, telephone number, and email address (if any);
b. all grounds for the objection, accompanied by any legal support for the objection known to the objector
or objector’s counsel;
c. the number of times the objector has objected to a class action settlement within the five years preceding
the date that the objector files the objection, the caption of each case in which the objector has made such
objection, and a copy of any orders related to or ruling upon the objector’s prior objections that were issued
by the trial and appellate courts in each listed case;
d. the identity of all counsel (if any) who represent the objector, including any former or current counsel
who may be entitled to compensation for any reason related to the objection to the Settlement and/or
Application for Attorneys’ Fees, Costs, and Service Awards, and whether they will appear at the Final
Approval Hearing;
6
e. the number of times in which the objector’s counsel and/or counsel’s law firm have objected to a class
action settlement within the five years preceding the date of the filed objection, the caption of each case in
which counsel or the firm has made such objection and a copy of any orders related to or ruling upon
counsel’s or the counsel’s law firm’s prior objections that were issued by the trial and appellate courts in
each listed case in which the objector’s counsel and/or counsel’s law firm have objected to a class action
settlement within the preceding five years;
f. a list of all persons who will be called to testify at the Final Approval Hearing in support of the objection
(if any);
g. a statement confirming whether the objector intends to personally appear and/or testify at the Final
Approval Hearing; and
h. the objector’s signature (an attorney’s signature is not sufficient).
Class Counsel and/or Defendant’s Counsel may conduct limited discovery on any objector or objector’s
counsel, including taking depositions and propounding document requests.
To be timely, written notice of an objection in the appropriate form must be mailed, postmarked no later than
September 21, 2026, to the following:
Clerk of the Court Class Counsel Defendant’s Counsel Settlement Administrator
Clerk of the Court Tonyia Johnson David Ross Community Connections
11th Judicial Circuit in Shamis & Gentile, P.A. Wilson Elser LLP Data Incidents
and for Miami-Dade 14 NE 1st Ave, Suite 705 1500 K St., NW Attn: Objections
County, Florida Miami, FL 33136 Suite 330 PO Box 19504
73 W Flagler St, Miami, Washington, DC 20005 Irvine, CA 92623
FL 33130 Scott Edelsberg
Edelsberg Law, P.A. Sara McLaughlin
20900 NE 30th Ave, Ste 417 Wilson Elser LLP
Aventura, FL 33180 111 North Orange Ave,
Suite 1200
Orlando, FL 32801
21. What is the difference between objecting and asking to opt-out?
Objecting is simply telling the Court you do not like something about the Settlement. You can object only if you
stay in the Settlement Class (meaning you do not opt out of the Settlement). Opting out of the Settlement is
telling the Court you do not want to be part of the Settlement Class or the Settlement. If you opt out, you cannot
object to the Settlement.
THE FINAL APPROVAL HEARING
22. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Final Approval Hearing on October 21, 2026, at 1:30 p.m., before Judge Mavel Ruiz at
11th Judicial Circuit in and for Miami-Dade County, Florida, Department CA04, located at 73 W Flagler St,
Miami, FL 33130.
At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and decide
whether to approve the Settlement, Class Counsel’s application for attorneys’ fees, costs, and the service awards
to Plaintiffs. If there are objections, the Court will consider them. The Court may also listen to people who have
asked to speak at the hearing. You may attend the hearing at your own expense, or you may pay your own
lawyer to attend, but it is not necessary.
7
Note: The date and time of the Final Approval Hearing are subject to change. Any change will be posted at
www.CCDataSettlement.com.
23. Do I have to attend to 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 send an objection, you do not have to come to Court to speak about it. As long as you mail
your written objection on time, the Court will consider it.
24. May I speak at the Final Approval Hearing?
Yes, as long as you do not exclude yourself or opt out, you can (but do not have to) participate and speak for
yourself in the Action about the Settlement. This is called making an appearance. You also can have your own
lawyer speak for you, but you will have to pay for the lawyer yourself.
If you want to appear, or if you want your own lawyer instead of Class Counsel to speak for you at the hearing,
you must follow all of the procedures for objecting to the Settlement listed in Question 20 and specifically
include a statement whether you and your counsel (if any) will appear at the Final Approval Hearing.
IF YOU DO NOTHING
25. What happens if I do nothing at all?
If you are a Settlement Class Member and you do nothing, you will not receive any Settlement benefits. You
will give up rights explained in the “Opting Out from the Settlement” section of this Notice, including your
right to start a lawsuit, or be part of any other lawsuit against Defendant or any of the Released Parties about the
legal issues in the Action that are released by the Settlement Agreement.
GETTING MORE INFORMATION
26. How do I get more information?
This Notice summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement.
The Settlement Agreement and other related documents are available at www.CCDataSettlement.com. If
you have questions, contact the Settlement Administrator at toll-free 1-888-506-1361 or email
[email protected].
PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE REGARDING THIS
NOTICE.
8