4NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Castenie et al., v. NJ Lenders Corp
Case No. PAS-L-001210-26
Superior Court for Passaic County, New Jersey
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE AUGUST 2025
NJ LENDERS CORP, 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 NJ Lenders Corp (“NJ Lenders” or “Defendant”) in a class action
lawsuit. This case is about the targeted cyberattack on NJ Lenders' computer systems that occurred
in August 2025 (the “Data Incident”). Certain files that contained Private Information were
accessed. These files may have contained personal information such as name; Social Security
numbers; and/or other non-public personally identifiable information.
• The lawsuit is called Castenie et al., v. NJ Lenders Corp, Case No. PAS-L-001210-26. It is pending in
the Superior Court for Passaic County, New Jersey (the “Litigation”).
• NJ Lenders 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.
• NJ Lenders' 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 NJ Lenders.
• 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 October 1, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.NJLendersDataSettlement.com. If you prefer, you can
download the Claim Form from the Settlement Website and mail it
to the Settlement Administrator.
OPT-OUT OF THE You can choose to opt-out of the Settlement and receive no Cash September 16, 2026
SETTLEMENT Payment or Credit Monitoring. 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 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 Class Member 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. 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 and released 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 ................................................ 5
THE LAWYERS REPRESENTING YOU ............................................................................... 6
OPTING OUT FROM THE SETTLEMENT ............................................................................ 6
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 for Passaic County, New Jersey, 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 Castenie et al., v. NJ Lenders Corp, Case No. PAS-L-001210-26. It is pending in the
Superior Court for Passaic County, New Jersey. The people that filed this lawsuit are called the “Plaintiffs” (or
“Class Representatives”) and the company they sued, NJ Lenders Corp, is called the “Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during an August 2025 targeted cyberattack on NJ Lenders' computer systems,
certain files that contained Private Information were accessed. These files may have contained personal
information such as name; Social Security numbers; and/or other non-public personally identifiable
information.
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 of the settlement. In this proposed Settlement, the Class Representatives are Patrick Castenie;
David Garcia; and Brandy Albanese. Everyone included in this Action are Settlement Class Members.
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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 to avoid the costs and risks of a trial, and to allow the Settlement Class Members to receive
benefits from the Settlement. The Plaintiffs and their attorneys think the Settlement is best for all Settlement
Class Members.
Who is in the Settlement?
5. Who is included in the Settlement?
The court has defined the Settlement Class this way: “All Persons who received direct notice that their Private
Information may have been impacted in the Data Incident.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (a) all persons who are directors and officers of Defendant; (b)
governmental entities; and (c) the Judge assigned to the Action, that Judge’s immediate family, and Court
staff.
If you are not sure whether you are a Settlement 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) 421-7307
• By mail: NJ Lenders Data Incident Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at www.NJLendersDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Credit Monitoring and one of two Cash Payment options. The
benefits are explained in more detail below.
CREDIT MONITORING. All Settlement Class Members are eligible to enroll in one year of CyEx Financial
Shield Complete. Enrollment codes have been sent to all Settlement Class Members, and you will receive
activation instructions after the Settlement has received final approval.
If you no longer have your enrollment code, please contact the Administrator.
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
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If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
CASH PAYMENTS. Settlement Class Members who have documented losses may claim a payment from
Cash Payment A – Documented Losses. Alternatively, Settlement Class Members may claim a one-time
payment from Cash Payment B – Alternate Cash. You may claim only one total payment from these options.
Cash Payment A – Documented Losses. If you incurred actual, documented out-of-pocket losses
due to the Data Incident, you can get back up to $2,500.00. The losses must have occurred between
August 18, 2025, and October 1, 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 receipts, to show how much you spent or lost. Your personal
certifications, declarations, or affidavits do not constitute reasonable documentation to make a valid
claim, but you may include that to provide clarification, context, or support for other submitted
reasonable documentation showing 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.
-OR-
Cash Payment B – Alternate Cash. Instead of Cash Payment A, 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: [email protected]
• Call toll free, 24/7: 1-(833) 421-7307
• By mail: NJ Lenders Data Incident Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
8. What claims am I releasing if I stay in the Settlement Class?
If you stay in the Settlement Class, you won’t be able to be part of any other lawsuit against NJ Lenders 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 Settlement Class. The Settlement Agreement
is available at www.NJLendersDataSettlement.com.
Submitting a Claim Form for a Settlement Payment
9. How do I submit a claim for a Settlement benefit?
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The fastest way to submit your Claim Form is online at www.NJLendersDataSettlement.com. If you prefer,
you can download a printable Claim Form from the website and mail it to the Settlement Administrator at:
NJ Lenders Data Incident Settlement
c/o Settlement Administrator
PO 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) 421-7307, 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 October 1, 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 1, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a Final Approval Hearing on October 16, 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.
Please be patient.
The Lawyers Representing You
12. Do I have a lawyer in the case?
Yes, the Court has appointed attorneys Kenneth J. Grunfeld, Leanna A. Loginov and Mark K. Svensson, to
represent you and other Settlement 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 $280,000.00 as reasonable attorneys' fees and costs of
litigation. This amount will be paid by NJ Lenders.
Class Counsel will also ask for Service Award payments of $2,000.00 for each of the Class Representatives.
Service Award payments will also be paid by NJ Lenders.
Opting-Out 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
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is called an Opt-Out Request.
If you opt-out, 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 opt-out. However, you will keep any rights you may have to
sue NJ Lenders on your own about the legal issues in this case.
The deadline to opt-out from the Settlement is September 16, 2026.
To be valid, your Opt-Out Request must have the following information:
(1) the name of the Litigation: Castenie et al., v. NJ Lenders Corp, Case No. PAS-L-001210-26, pending
in the Superior Court for Passaic County, New Jersey;
(2) your full name, mailing address, telephone number, and email address;
(3) personal signature; and
(4) the words “Opt-Out Request” 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:
NJ Lenders Data Incident Settlement
ATTN: Exclusion Request
PO Box 25226
Santa Ana, CA 92799-9958
Your Opt-Out Request must be submitted and postmarked 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 Settlement 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 opted-out 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: Castenie et al., v. NJ Lenders Corp, Case No. PAS-L-001210-26, pending
in the Superior Court for Passaic County, New Jersey;
(2) your full name, mailing address, telephone number, and email address (if any);
(3) all grounds for the objection, accompanied by any legal support for the objection known to the
objector or objector’s counsel;
(4) 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;
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(5) the identity of all counsel 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 Award;
(6) 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;
(7) the identity of all counsel (if any) representing the objector, and whether they will appear at the
Final Approval Hearing;
(8) a list of all persons who will be called to testify at the Final Approval Hearing in support of the
objection (if any);
(9) a statement confirming whether the objector intends to personally appear and/or testify at the
Final Approval Hearing; and
(8) your signature (if you have hired your own lawyer, their signature is not sufficient).
For your objection to be considered, 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 by U.S. Mail to the Settlement Administrator, Class
Counsel, and Defendant’s Counsel.
Clerk of the Court Settlement Administrator
Clerk of the Court NJ Lenders Data Incident Settlement
77 Hamilton Street ATTN: Objections
Paterson, NJ 07505 PO Box 25226
Santa Ana, CA 92799-9958
Class Counsel Counsel for Defendants
Leanna A. Loginov Spencer Persson
SHAMIS & GENTILE P.A. BAKER & HOSTETLER, LLP
14 NE 1st Ave., Ste. 705 1900 Avenue of Stars, Suite 2700
Miami, FL 33132 Los Angeles, CA 90067
Mark K. Svensson Eric R. Fish
MILBERG, PLLC BAKER & HOSTETLER, LLP
405 East 50th St. 45 Rockefeller Plaza
New York, NY 10022 New York, NY 10111
Kenneth J. Grunfeld
KOPELOWITZ OSTROW P.A.
65 Overhill Rd.
Bala Cynwyd, PA 19004
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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 opt-out from the Settlement. Opting out from the Settlement is 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 on October 16, 2026, at 11:00 a.m. Eastern Time, in Courtroom 322 of
the Superior Court for Passaic County, New Jersey, at 77 Hamilton Street, Paterson, NJ 07505.
At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The court will also
decide Class Counsel’s request for an attorneys’ fees and costs award and the request for a Service Award
to the Class Representatives. The Court will also consider any timely objections to the Settlement.
If you are a Settlement 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.NJLendersDataSettlement.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.NJLendersDataSettlement.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) 421-7307
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Questions? Call 1- (833) 421-7307 Toll-Free or Visit www.NJLendersDataSettlement.com
• By mail: NJ Lenders Data Incident Settlement
c/o Settlement Administrator
PO 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, 77 Hamilton
Street, Paterson, NJ 07505.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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