NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
In re Hillcrest Convalescent Center, Inc. Data Breach Litigation
Case No. 25CV002700-310
Superior Court of Durham County, North Carolina
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE JUNE 2024
HILLCREST CONVALESCENT CENTER, INC., 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 Hillcrest Convalescent Center, Inc. (“Hillcrest” or “Defendant”)
in a class action lawsuit. This case is about the cyberattack on Hillcrest's computer systems that
occurred in June 2024 which may have resulted in the unauthorized access to and/or acquisition of
certain Private Information (the “Data Incident”). The Private Information that may have been
impacted includes names; addresses; financial account information; dates of birth; driver's license
numbers; Social Security Numbers; and other government issued ID numbers; as well as medical
treatment; health insurance; and provider information.
• The lawsuit is called In re Hillcrest Convalescent Center, Inc. Data Breach Litigation, Case No.
25CV002700-310. It is pending in the Superior Court of Durham County, North Carolina (the
“Litigation”).
• Hillcrest 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.
• Hillcrest's records indicate that you are a Settlement Class Member, and entitled to benefits under
the Settlement. You may have received a previous notice directly from Hillcrest.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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 August 26, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.HCCDataSettlement.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 July 27, 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 July 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.
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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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 ...................................................................... 9
IF I DO NOTHING ........................................................................................................... 9
GETTING MORE INFORMATION ...................................................................................... 9
Basic Information
1. Why was this Notice issued?
The Superior Court of Durham County, North Carolina, 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 Hillcrest Convalescent Center, Inc. Data Breach Litigation, Case No. 25CV002700-
310. It is pending in the Superior Court of Durham County, North Carolina. The people that filed this lawsuit
are called the “Plaintiffs” (or “Class Representatives”) and the company they sued, Hillcrest Convalescent
Center, Inc., is called the “Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the June 2024 cyberattack on Hillcrest's computer systems, certain files that
contained private information were accessed and/or acquired. These files may have contained private
information such as names; addresses; financial account information; dates of birth; driver's license
numbers; Social Security Numbers; and other government issued ID numbers; as well as medical treatment;
health insurance; and provider information. Hillcrest denies the allegations in the lawsuit or any wrongdoing
or liability.
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 Sarah Beddingfield; Nakia
Brandon; and Tanita Eakins. Everyone included in this Action are the Class Members.
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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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 without admission of liability 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 attorneys 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 Settlement Class as: “All living individuals in the United States whose Private
Information was implicated in the Data Incident.”
The Settlement Class includes the Group 1 Settlement Subclass and the Group 2 Settlement Subclass,
defined as follows: Group 1 Settlement Subclass Members: Settlement Class Members who did have their
Social Security number(s) among the Private Information potentially impacted in the Data Incident. Group 2
Settlement Subclass Members: Settlement Class Members who did not have their Social Security number(s)
among the Private Information potentially impacted in the Data Incident. A Settlement Class Member is either
a Group 1 Settlement Subclass Member or Group 2 Settlement Subclass Member; not both.
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) Hillcrest and its officers, directors, and related companies; (2)
governmental entities; and (3) the Judge in this case, and the Judge’s family and staff.
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: 1-833-421-7232
• By mail: Hillcrest 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.HCCDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Credit Monitoring Services and reimbursement for Documented
Losses. Group 1 Settlement Subclass Members also have the option of a $50.00 Alternative Cash Payment.
These benefits are explained in more detail below.
CREDIT MONITORING SERVICES. All Settlement Class Members are eligible to enroll in two years of CyEx
Identity Defense Complete. This comprehensive service comes with $1 million in identity theft insurance, and
includes:
• real time monitoring of your credit file
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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• dark web scanning
• comprehensive public records monitoring
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
Documented Losses. All Settlement Class Members may file a claim for reimbursement of incurred actual,
documented out-of-pocket losses due to the Data Incident, up to $2,500.00. The losses must have occurred
between June 27, 2024, and August 26, 2026.
This benefit covers out-of-pocket expenses like:
• losses because of identity theft or fraud
• 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 bank statements or 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.
Alternative Cash Payment (Group 1 only). Instead of any other available benefit, Group 1 Settlement
Subclass Members may claim a one-time cash payment. This payment is expected to be $50.00. You do not
have to provide any proof or explanation to claim this payment.
Group 2 Settlement Subclass Members are not eligible to submit a Claim for Alternative Cash 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: 1-833-421-7232
• By mail: Hillcrest 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 Hillcrest about the issues that
this Settlement covers. The “Releases” section of the Settlement Agreement (Section XI) describes the legal
claims that you give up if you remain in the Class. The Settlement Agreement is available at
www.HCCDataSettlement.com.
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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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 at www.HCCDataSettlement.com. If you prefer, you can
download a printable Claim Form from the website and mail it to the Settlement Administrator at:
Hillcrest 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, 1-833-
421-7232, by email [email protected], 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 August 26, 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 August 26, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on August 24, 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 Mariya Weekes of Milberg PLLC; A. Brooke Murphy of Murphy Law
Firm; and Phillip J. Krzeski of Chestnut Cambronne PA, 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 $325,000.00 as reasonable attorneys' fees and costs of litigation.
This amount will be paid by Hillcrest.
Class Counsel will also ask for Service Award payments of $2,500.00 for each of the Class Representatives.
Service Award payments will also be paid by Hillcrest.
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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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
Settlement benefits or payment. However, you will keep any rights you may have to sue Hillcrest 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 July 27, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: In re Hillcrest Convalescent Center, Inc. Data Breach Litigation, Case No.
25CV002700-310, pending in the Superior Court of Durham County, North Carolina;
(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:
Hillcrest 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 July 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:
(1) the name of the Litigation: In re Hillcrest Convalescent Center, Inc. Data Breach Litigation, Case No.
25CV002700-310, pending in the Superior Court of Durham County, North Carolina;
(2) your full name, mailing address, telephone number, and email address;
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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(3) a clear description of all the reasons you object; include any legal support, such as documents, you
may have for your objection;
(4) whether the objection applies only to you, or to other Class Members, as well;
(5) if you have hired your own lawyer to represent you for this objection, provide their name, bar number,
and contact information;
(6) 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;
(7) whether or not you or your lawyer would like to speak at the Final Approval Hearing;
(8) if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a
full list of both; and
(9) 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 July 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 Hillcrest Data Incident Settlement
16th Judicial District, Durham County ATTN: Objections
510 S. Dillard St. P.O. Box 25226
Durham, NC 27701 Santa Ana, CA 92799-9958
Class Counsel Counsel for Defendants
Mariya Weekes Allison Becker
Milberg PLLC GORDON REES SCULLY MANSUKHANI, LLP
333 SE 2nd Avenue, Suite 2000 150 Fayetteville Street, Suite 1120
Miami, FL, 33131 Raleigh, NC 27601
A. Brooke Murphy Joseph Salvo
MURPHY LAW FIRM John T. Mills
4116 Will Rogers Parkway, Suite 700 GORDON REES SCULLY MANSUKHANI, LLP
Oklahoma City, OK 73108 One Battery Park Plaza, 28th Floor
New York, NY 10004
Philip Krzeski
CHESTNUT CAMBRONNE PA
100 Washington Avenue South, Suite 1700
Minneapolis, MN 55401
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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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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The Court’s Final Approval Hearing
18. When is the Court’s Final Approval Hearing?
The Court will hold a Final Approval Hearing on August 24, 2026 at 10:00 a.m. Eastern Time, in the Superior
Court of Durham County, North Carolina, at 16th Judicial District, Durham County, 510 S. Dillard St. Durham,
NC 27701.
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 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.HCCDataSettlement.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.HCCDataSettlement.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: 1-833-421-7232
• By mail: Hillcrest Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 16th Judicial
District, Durham County, 510 S. Dillard St. Durham, NC 27701.
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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Questions? Call 1-XXX-XXX-XXXX Toll-Free or Visit www.[SettlementWebsite].com
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