NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
White v. Mortgage Investors Group, Inc.
Case No. 25-0350-III
Chancery Court for Davidson County, Tennessee
IF YOUR PRIVATE INFORMATION WAS IMPLICATED IN THE
DECEMBER 2024 MORTGAGE INVESTORS GROUP, INC., DATA INCIDENT,
A PROPOSED CLASS ACTION SETTLEMENT MAY AFFECT YOUR RIGHTS,
AND ENTITLE YOU TO SETTLEMENT BENEFITS.
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 Mortgage Investors Group, Inc. (“MIG” or “Defendant”) in a
class action lawsuit. This case is about the cyberattack on MIG's computer systems that occurred in
December 2024 (the “Data Incident”). Certain files that contained private information were
accessible. These files may have contained personal information such as names and financial
information.
• The lawsuit is called White v. Mortgage Investors Group, Inc., Case No. 25-0350-III. It is pending in
the Chancery Court for Davidson County, Tennessee (the “Litigation”).
• MIG 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.
• MIG'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 MIG.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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Questions? Call 1- (833) 421-7351 Toll-Free or Visit www.MIGDataSettlement.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 November 19, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.MIGDataSettlement.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 October 20, 2026
SETTLEMENT Settlement benefits. 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 20, 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 Chancery Court for Davidson County, Tennessee, 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 White v. Mortgage Investors Group, Inc., Case No. 25-0350-III. It is pending in the
Chancery Court for Davidson County, Tennessee. The person that filed this lawsuit is called the “Plaintiff” (or
“Class Representative”) and the company he sued, Mortgage Investors Group, Inc., is called the
“Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the December 2024 cyberattack on MIG's computer systems, certain files that
contained private information were accessible. These files may have contained personal information such as
names and financial information.
3. What is a class action?
In a class action, one or more individuals sue on behalf of other people who they allege have similar claims.
These individuals are called the “Plaintiffs” or “Class Representatives.” Together, after a court grants
certification, 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 of the settlement. In this Settlement,
the Class Representative is Wassell White. Everyone included in this Action is a Class Member.
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 his 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 whose PII was implicated in the Data Incident
involving Mortgage Investors Group, Inc.” In this sentence, PII means Personally Identifiable Information.
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) MIG and its officers and directors; (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: 1- (833) 421-7351
• By mail: MIG 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.MIGDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
MIG has agreed to pay for a number of Class benefits, which are explained below.
Credit Monitoring. All Class Members are eligible to enroll in one year 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.
Reimbursement for Documented Out-of-Pocket Expenses and Losses. If you incurred actual, documented
out-of-pocket losses due to the Data Incident, you can get back up to $2,000.00. The losses must have
occurred between December 12, 2024, and November 19, 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
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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. Instead of any other payments, you may claim a one-time $45.00 cash payment.
You do not have to provide any proof or explanation to claim this payment.
MIG’s obligation is capped at $925,000.00. This means that if the total value of litigation fees and expenses;
costs of administration; and Class benefits claimed is over $925,000.00, everyone’s payments will be
reduced pro rata so that they add up to $925,000.00.
A full description of how this works is available in the Settlement Agreement, at
www.MIGDataSettlement.com.
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) 421-7351
• By mail: MIG 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 MIG 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.MIGDataSettlement.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.MIGDataSettlement.com. If you prefer, you can
download a printable Claim Form from the website and mail it to the Settlement Administrator at:
MIG 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) 421-7351, 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 November 19, 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 November 19, 2026.
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Questions? Call 1- (833) 421-7351 Toll-Free or Visit www.MIGDataSettlement.com
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on November 10, 2026, at 11:00am (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 J. Gerard Stranch, IV and Grayson Wells of Stranch, Jennings & Garvey,
PLLC; Lynn Toops of Cohen & Malad, LLP; and Raina Borrelli of Strauss Borrelli PLLC, 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 up to $270,000.00 as reasonable attorneys' fees and
reimbursement of litigation costs. This amount will be paid by MIG.
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 MIG.
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 MIG 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 20, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: White v. Mortgage Investors Group, Inc., Case No. 25-0350-III, pending in
the Chancery Court for Davidson County, Tennessee;
(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.
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Questions? Call 1- (833) 421-7351 Toll-Free or Visit www.MIGDataSettlement.com
Mail your Request for Exclusion to the Settlement Administrator at:
MIG Data Incident Settlement
ATTN: Exclusion Request
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be postmarked by October 20, 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: White v. Mortgage Investors Group, Inc., Case No. 25-0350-III, pending
in the Chancery Court for Davidson County, Tennessee;
(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 October 20,
2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and
counsel for Defendant.
Clerk of the Court Settlement Administrator
Clerk of the Court MIG Data Incident Settlement
Chancery Court for Davidson County, ATTN: Objections
Tennessee P.O. Box 25226
1 Public Square, #308 Santa Ana, CA 92799-9958
Nashville, TN 37201
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Class Counsel Counsel for Defendant
J. Gerard Stranch, IV David M. Ross
Grayson Wells Wilson Elser LLP
Stranch, Jennings & Garvey, PLLC 1500 K Street, NW, Suite 330
The Freedom Center Washington, DC 20005
223 Rosa L. Parks Avenue, Suite 200
Nashville, TN 37203
Lynn Toops
CohenMalad, LLP
One Indiana Square, Suite 1400
Indianapolis, IN 46204
Raina Borrelli
Strauss Borrelli PLLC
980 N. Michigan Avenue, Suite 1610
Chicago, IL 60611
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 10, 2026 at 11:00 am Central Time, in Courtroom
407 of the Chancery Court for Davidson County, Tennessee, at 1 Public Square, Nashville, TN 37201.
At the final approval hearing, the Court will decide whether to approve the Settlement. The Court will also
decide how much 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.MIGDataSettlement.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.
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Questions? Call 1- (833) 421-7351 Toll-Free or Visit www.MIGDataSettlement.com
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.MIGDataSettlement.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) 421-7351
• By mail: MIG 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, Chancery
Court for Davidson County, Tennessee, at 1 Public Square, #308, Nashville, TN 37201.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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