NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Kramer v. First Baptist Church of Hammond, Indiana, Inc.
Case No. 45D01-2509-CE-62
Indiana Commercial Court in the Lake County Superior Court
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE JULY 2025
FIRST BAPTIST CHURCH OF HAMMOND, INDIANA, INC., DATA SECURITY
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 First Baptist Church of Hammond, Indiana, Inc. (“FBC” or
“Defendant”) in a class action lawsuit. This case is about the targeted cyberattack on FBC's
computer systems that occurred in July 2025 (the “Data Security Incident”). Certain files that
contained private information were accessed. These files may have contained personal information
such as names and Social Security numbers.
• The lawsuit is called Kramer v. First Baptist Church of Hammond, Indiana, Inc., Case No. 45D01-
2509-CE-62. It is pending in the Indiana Commercial Court in the Lake County Superior Court (the
“Litigation”).
• FBC 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.
• FBC'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 FBC.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 1 of 9
Questions? Call (833) 421-7348 Toll-Free or Visit www.FBCDataSettlement.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 September 30, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.FBCDataSettlement.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 September 16, 2026
SETTLEMENT or payment. This option allows you to sue, continue to sue, or be
part of another lawsuit against the Defendants 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 September 16, 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.
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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 Indiana Commercial Court in the Lake County Superior Court, 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 Kramer v. First Baptist Church of Hammond, Indiana, Inc., Case No. 45D01-2509-CE-62.
It is pending in the Indiana Commercial Court in the Lake County Superior Court. The person that filed this
lawsuit is called the “Plaintiff” (or “Class Representative”) and the company they sued, First Baptist Church
of Hammond, Indiana, Inc., is called the “Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the July 2025 targeted cyberattack on FBC's computer systems, certain files
that contained private information were accessed. These files may have contained personal information such
as names and Social Security numbers.
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 Representative is Hannah Kramer. Everyone
included in this Action are the Class Members.
4. Why is there a Settlement?
The Court did not decide whether the Plaintiff 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 Plaintiff 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 persons whose personally identifiable information was
accessed and/or acquired by an unauthorized party as a result of the Data Security Incident.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) FBC and its officers, directors, and related companies; (2) governmental
entities; (3) the Judge in this case, and the Judge’s family and staff; and (4) anyone who validly excludes
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:
• Email: [email protected]
• Call toll free, 24/7: (833) 421-7348
• By mail: FBC Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also view the Settlement Agreement at www.FBCDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
FBC has agreed to provide a number of different cash payment options, which are explained below.
Reimbursement for Ordinary Documented Out-of-Pocket Expenses. If you incurred actual, documented
out-of-pocket expenses due to the Data Security Incident, you can get back up to $450.00. The losses must
have occurred between July 1, 2025, and September 30, 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.
Reimbursement for Extraordinary Documented Out-of-Pocket Losses. If you lost money because of
identity theft or fraud, you can get back up to $4,500.00.
You will need to show that:
• the theft or fraud was probably caused by the Data Security Incident
• the losses are not already covered by Ordinary Documented Out-of-Pocket Expenses
• you tried to prevent the loss or get your money back, such as by using insurance you already have
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The losses must have occurred between July 1, 2025, and September 30, 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.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Lost Time. Class Members who spent time responding to the Data Security 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 Security Incident. Some examples include things
like:
• changing your passwords
• investigating suspicious activity in your accounts
• researching the Data Security Incident
You must briefly describe how you spent this time.
Alternative Cash Payment. Instead of any other cash payment option, you may claim a one-time $50.00 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: [email protected]
• Call toll free, 24/7: (833) 421-7348
By mail: FBC Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
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 FBC about the issues that this
Settlement covers. The “Releases” section of the Settlement Agreement (Section 11) describes the legal
claims that you give up if you remain in the Class. The Settlement Agreement is available at
www.FBCDataSettlement.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.FBCDataSettlement.com. If you prefer, you can
download a printable Claim Form from the website and mail it to the Settlement Administrator at:
FBC Data Security 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) 421-7348, by email [email protected], or by U.S. mail at the address above.
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 5 of 9
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10. Are there any important Settlement payment deadlines?
If you are submitting a Claim Form online, you must do so by September 30, 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 September 30, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on November 30, 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 attorneys Lynn A. Toops and Amina A. Thomas 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 $250,000.00 as reasonable attorneys' fees and reimbursement
of litigation costs. This amount will be paid by FBC.
Class Counsel will also ask for a Service Award Payment of $2,500.00 for the Class Representative. The
Service Award Payment will also be paid by FBC.
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
Settlement benefits or payment. However, you will keep any rights you may have to sue FBC 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 16, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: Kramer v. First Baptist Church of Hammond, Indiana, Inc., Case No.
45D01-2509-CE-62, pending in the Indiana Commercial Court in the Lake County Superior Court;
(2) your full name, mailing address, telephone number, and email address;
(3) personal signature; and
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 6 of 9
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(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:
FBC Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Your Request for Exclusion must be submitted, postmarked, or emailed by September 16, 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:
(1) the name of the Litigation: Kramer v. First Baptist Church of Hammond, Indiana, Inc., Case No.
45D01-2509-CE-62, pending in the Indiana Commercial Court in the Lake County Superior Court;
(2) your full name, mailing address, telephone number, and email address;
(3) a clear description of all the reasons you object; include any legal support, such as documents,
you may have for your objection;
(4) if you have hired your own lawyer to represent you for this objection, provide their name, bar
number, and contact information;
(5) if you or your lawyer have objected in any other cases in the past five years, list the names, courts,
the orders ruling on your objections, and civil action numbers for each of those cases;
(6) whether or not you or your lawyer would like to speak at the Final Approval Hearing;
(7) if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a
full list of both;
(8) your signature (if you have hired your own lawyer, their signature is not sufficient).
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 September
16, 2026. You must also send a copy of the objection to the Settlement Administrator.
Clerk of the Court Settlement Administrator
Clerk of the Court FBC Data Security Incident Settlement
232 Russell Street c/o Settlement Administrator
Hammond, IN 46320 P.O. Box 25226
Santa Ana, CA 92799
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 7 of 9
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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.
The Court’s Final Approval Hearing
18. When is the Court’s Final Approval Hearing?
The Court will hold a final approval hearing on November 30, 2026 at 1:00 PM Central Time, at the Lake
Superior Court No. 1, 232 Russell Street Hammond, IN 46320, in person.
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 Payment to the Class
Representative. 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.FBCDataSettlement.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.FBCDataSettlement.com.
If you have additional questions, you can ask for free help any time by contacting the Settlement
Administrator at:
• Email: [email protected]
• Call toll free, 24/7: (833) 421-7348
• By mail: FBC Data Security Incident Settlement
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 8 of 9
Questions? Call (833) 421-7348 Toll-Free or Visit www.FBCDataSettlement.com
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 232 Russell
Street Hammond, IN 46320.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
Kramer v. First Baptist Church of Hammond, Indiana, Inc. Page 9 of 9
Questions? Call (833) 421-7348 Toll-Free or Visit www.FBCDataSettlement.com
