Circuit Court of the City of St. Louis, Missouri
In re: Sansone Group, LLC, Data Breach Litigation
Case No. 2522-CC01749
NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE
MARCH 2025 SANSONE GROUP, LLC, 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 Sansone Group, LLC (“Sansone” or “Defendant”) in a class
action lawsuit. This case is about the targeted cyberattack on Sansone's computer systems that
occurred in March 2025 (the “Data Incident”). Certain files that contained private information may
have been accessed. These files may have contained personal information such as names, Social
Security numbers, and/or other personally identifiable information.
• The lawsuit is called In re: Sansone Group, LLC, Data Breach Litigation, Case No. 2522-CC01749. It
is pending in the Circuit Court of the City of St. Louis, Missouri (the “Action”).
• Sansone 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 Action.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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CaseID: 9585
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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 13, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
https://SansoneDataIncident.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 28, 2026
SETTLEMENT or payment. This option allows you to sue, continue to sue, or be
part of another lawsuit against Sansone 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 28, 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 Sansone
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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CaseID: 9585
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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 Circuit Court of the City of St. Louis, Missouri, 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: Sansone Group, LLC, Data Breach Litigation, Case No. 2522-CC01749. It is pending
in the Circuit Court of the City of St. Louis, Missouri. The people who filed this lawsuit are called the
“Plaintiffs” (or “Class Representatives”) and the company they sued, Sansone Group, LLC, is called the
“Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the March 2025 targeted cyberattack on Sansone's computer systems,
certain files that contained private information were accessed. These files may have contained personal
information such as names, Social Security numbers, and/or other 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 from the settlement. In this Settlement, the Class Representatives are Staci Laurino and Larry
Morgan. Everyone included in this Action are the Class Members.
4. Why is there a Settlement?
The Court did not decide whether the Plaintiffs or Sansone 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 Plaintiffs and their attorneys think the Settlement is best for all Class Members.
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CaseID: 9585
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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 living individuals in the United States whose Private Information
may have been impacted in the Data Incident, including all individuals who received notice of the Data
Incident from Sansone.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (a) all persons who are directors and officers of Sansone, or its respective
subsidiaries and affiliated companies; (b) governmental entities; (c) the Judge(s) assigned to the Action, the
Judge’s immediate family, Court staff, and counsel for the Parties; and (d) any Settlement Class Member who
properly and timely opts-out of 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) 421-7335
• By mail:
Sansone Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at https://SansoneDataIncident.com.
The Settlement Benefits
7. What does the Settlement provide?
Sansone has agreed to pay for a number of Class benefits, which are explained below. All Class Members are
eligible to claim two years of Credit Monitoring services from CyEx Financial Shield Complete, and one of
two cash payment options.
CREDIT MONITORING. All Class Members are eligible to enroll in two years 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.
CASH PAYMENTS
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CaseID: 9585
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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 $3,500.00. The losses must have occurred between
March 22, 2025, and October 13, 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.
Cash Payment B – Alternate Cash. 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.
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) 421-7335
• By mail:
Sansone 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 Sansone about the issues that
this Settlement covers. The “Releases” section of the Settlement Agreement (Section XII) describes the legal
claims that you give up if you remain in the Class. The Settlement Agreement is available at
https://SansoneDataIncident.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 https://SansoneDataIncident.com. If you prefer, you
can download a printable Claim Form from the website and mail it to the Settlement Administrator at:
Sansone Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
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CaseID: 9585
Questions? Call (833) 421-7335 Toll-Free or Visit https://SansoneDataIncident.com
Santa Ana, CA 92799-9958
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free,
(833) 421-7335, 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 13, 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 13, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on October 28, 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 Jeff Ostrow of Kopelowitz Ostrow P.A.; Raina Borrelli of Strauss
Borrelli PLLC; and Maureen Brady of McShane & Brady LLC, 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 $170,000.00 as reasonable attorneys' fees and reimbursement
of litigation costs. This amount will be paid by Sansone.
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 Sansone.
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 Sansone 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.
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CaseID: 9585
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The deadline to exclude yourself from the Settlement is September 28, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Action: In re: Sansone Group, LLC, Data Breach Litigation, Case No. 2522-
CC01749, pending in the Circuit Court of the City of St. Louis, Missouri;
(2) your full name, mailing address, telephone number, and email address (if any);
(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:
Sansone Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be postmarked by September 28, 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:
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 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 the Application for Attorneys’ Fees, Costs, and Service Awards, and
whether they will appear at the Final Approval Hearing;
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CaseID: 9585
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e. the number of times in which the objector’s counsel and/or the objector’s 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 on the objection issued by the trial
and appellate courts in each such listed case;
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. if the objector or the objector’s attorney uses artificial intelligence to assist in drafting their
objection, a disclosure of the use of artificial intelligence and the platform used;
h. a statement confirming whether the objector and/or objector’s counsel intends to
personally appear and/or testify at the Final Approval Hearing; and
i. the objector’s signature (an attorney’s 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
28, 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 Sansone Data Incident Settlement
Thomas Kloeppinger c/o Settlement Administrator
10 North Tucker Boulevard P.O. Box 25226
St. Louis, Missouri 63101 Santa Ana, CA 92799-9958
Class Counsel Counsel for Defendants
Jeff Ostrow Timothy J. Lowe
Kopelowitz Ostrow P.A. McDonald Hopkins PLC
1 West Las Olas Boulevard, 5th Floor 39533 Woodward Avenue, Suite 318
Fort Lauderdale, FL 33301 Bloomfield Hills, MI 48304
Raina C. Borrelli Sydney K. Bell
Strauss Borrelli PLLC McDonald Hopkins LLC
One Magnificent Mile 600 Superior Avenue East, Suite 2100
980 North Michigan Avenue, Suite 1610 Cleveland, OH 44114
Chicago, IL 60611
Maureen M. Brady
McShane & Brady, LLC
1656 Washington Street, Suite 120
Kansas City, MO 64108
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CaseID: 9585
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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 on October 28, 2026, at 9:00 a.m., Central Time, of the Circuit Court of
the City of St. Louis, Missouri, at Carnahan Courthouse, 1114 Market Street, St. Louis, Missouri 63101.
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
https://SansoneDataIncident.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, https://SansoneDataIncident.com.
If you have additional questions, you can ask for free help any time by contacting the Settlement
Administrator at:
• Email: [email protected]
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CaseID: 9585
Questions? Call (833) 421-7335 Toll-Free or Visit https://SansoneDataIncident.com
• Call toll free, 24/7: (833) 421-7335
• By mail:
Sansone 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, Thomas
Kloeppinger, 10 North Tucker Boulevard St. Louis, Missouri 63101.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT.
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CaseID: 9585
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