NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Harris, et al. v. Summit Medical Group, PLLC
Case No. 2-119-25
Circuit Court for Knox County, Tennessee
IF YOU RECEIVED A NOTICE OF A DATA INCIDENT FROM SUMMIT MEDICAL
GROUP, PLLC THAT CERTAIN OF YOUR PERSONAL INFORMATION WAS
IMPACTED IN A SEPTEMBER 2024 DATA INCIDENT,
A PROPOSED CLASS ACTION SETTLEMENT MAY AFFECT YOUR RIGHTS AND
ENTITLE YOU TO 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 Summit Medical Group, PLLC (“Summit Medical” or
“Defendant”) in a class action lawsuit. This case is about the targeted cyberattack on Summit
Medical's computer systems that occurred in September 2024 (the “Data Incident”). Certain files
that contained Private Information were potentially accessed. These files may have contained
personal information such as names; contact information; demographic information; medical
record numbers; provider names; dates of services; facilities of service; treatment information;
prescription information; health insurance information; and/or Social Security numbers.
• The lawsuit is called Harris, et al. v. Summit Medical Group, PLLC, Case No. 2-119-25. It is pending
in the Circuit Court for Knox County, Tennessee (the “Litigation”).
• Summit Medical denies that it did anything wrong.
• The parties have agreed to settle the lawsuit (the “Settlement”) to avoid the costs and risks,
disruptions, and uncertainties of continuing the Litigation.
• Summit Medical'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 Summit Medical.
• 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 November 4, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.SummitMedicalDataSettlement.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 October 20, 2026
SETTLEMENT Payment or Medical Data 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 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 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 ................................................ 6
THE LAWYERS REPRESENTING YOU ............................................................................... 6
OPTING OUT 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 .................................................................................... 10
Basic Information
1. Why was this Notice issued?
The Circuit Court for Knox 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 Harris, Laura, et al. v. Summit Medical Group, PLLC, Case No. 2-119-25. It is pending in
the Circuit Court for Knox County, Tennessee. The people who filed this lawsuit are called the “Plaintiffs” (or
“Class Representatives”) and the company they sued, Summit Medical Group, PLLC, is called the
“Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the September 2024 targeted cyberattack on Summit Medical's computer
systems, certain files that contained Private Information were accessed. These files may have contained
personal information such as names; contact information; demographic information; medical record
numbers; provider names; dates of services; facilities of service; treatment information; prescription
information; health insurance information; and/or 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 proposed Settlement, the Class Representatives are Laura Harris;
Christopher Harris; Scott Campion; J.B. through parent Jade Brown; and Jade Brown. Everyone included in
this Action are the 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 as: “All living individuals in the United States whose Private
Information was potentially compromised in the Data Incident, including all individuals who were mailed
notice of the Data Incident from Defendant.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (a) all persons who are directors and officers of Defendant, or its respective
subsidiaries and affiliated companies; (b) governmental entities; and (c) the Judge(s) assigned to the Action,
the 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-(866)-675-2936
• By mail: Summit Data Incident Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at www.SummitMedicalDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Medical Data Monitoring and two Cash Payment options. Any
cash payment may be decreased on a pro rata basis if more than $500,000 is claimed by eligible class
members. The benefits are explained in more detail below.
MEDICAL DATA MONITORING. All Settlement Class Members are eligible to enroll in two years of CyEx
Medical Shield Complete. This comprehensive service comes with $1 million of medical identity theft
insurance, and includes monitoring for:
• healthcare insurance ID exposure
• Medical Record Number (MRN) exposure
• unauthorized Health Savings Account (HSA) spending
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
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CASH PAYMENTS. Settlement Class Members who have documented losses may claim a payment from
Cash Payment A – Documented Losses. Additionally, Settlement Class Members who spent time responding
to the Data Incident may claim a payment from Cash Payment B – Lost Time.
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
September 2024, and November 4, 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.
Cash Payment B – Lost Time. Settlement Class Members who spent time responding to the Data
Incident may claim up to three hours, at $15.00 per hour, for a maximum of $45.00.
You must have spent the time on tasks related to the Data Incident. Some examples include things
like:
• changing your passwords
• investigating suspicious activity in your accounts
• researching the Data Incident
You must attest that the time claimed was spent as a result of the Data Incident.
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-(866)-675-2936
• By mail: Summit 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 Summit Medical
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.SummitMedicalDataSettlement.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.SummitMedicalDataSettlement.com. If you
prefer, you can download a printable Claim Form from the website and mail it to the Settlement Administrator
at:
Summit 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-(866)-675-2936, 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 4 ,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 4 ,2026.
11. When will the Settlement benefits be issued?
The Court will hold a Final Approval Hearing on November 19, 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 J. Gerard Stranch, IV of Stranch, Jennings & Garvey, PLLC; Jeff Ostrow
of Kopelowitz Ostrow, P.A.; Lisa A. White of Mason LLP; and Tyler J. Bean of Siri & Glimstad LLP, 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 $575,000.00 as reasonable attorneys' fees and costs of
litigation. This amount will be paid by Summit Medical.
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 Summit Medical.
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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
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 Summit Medical on your own about the legal issues in this case.
The deadline to opt-out from the Settlement is October 20, 2026.
To be valid, your Opt-Out Request must have the following information:
(1) the name of the Litigation: Harris, et al. v. Summit Medical Group, PLLC, Case No. 2-119-25,
pending in the Circuit Court for Knox County, Tennessee;
(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:
Summit Data Incident Settlement
ATTN: Exclusion Request
PO Box 25226
Santa Ana, CA 92799-9958
Your Opt-Out Request must be submitted and postmarked by October 20, 2026.
Commenting on or Objecting to the Settlement
16. How do I tell the Court if I 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: Harris, et al. v. Summit Medical Group, PLLC, Case No. 2-119-25,
pending in the Circuit Court for Knox County, Tennessee;
(2) your full name, mailing address, telephone number, and email address (if any);
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(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;
(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
the Application for Attorneys’ Fees, Costs, and Service Awards, and whether they will appear at the
Final Approval Hearing;
(6) 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;
(7) a list of all persons who will be called to testify at the Final Approval Hearing in support of the
objection (if any);
(8) a statement confirming whether the objector and/or objector’s counsel intends to personally
appear and/or testify at the Final Approval Hearing; and
(9) 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 October 20,
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 Summit Data Incident Settlement
State of Tennessee in the Circuit Court of Knox ATTN: Objections
County, Tennessee Civil Division PO Box 25226
400 Main Street, M30 Santa Ana, CA 92799-9958
Knoxville, TN 37902
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Class Counsel Counsel for Defendants
J. Girard Stranch, IV Carrie Dettmer Slye
Stranch, Jennings & Garvey PLLC Baker & Hostetler LLP
223 Rosa L. Parks Ave., Ste. 200 312 Walnut St., Ste. 3200
Nashville, TN 37203 Cincinnati, OH 45202
Jeff Ostrow
Kopelowitz Ostrow P.A.
1 West Las Olas Blvd., Ste. 500
Fort Lauderdale, FL 33301
Lisa A. White
Mason LLP
5335 Wisconsin Ave., NW, Ste. 640
Washington, DC 20015
Tyler J. Bean
Siri & Glimstad LLP
745 Fifth Ave., Ste. 500
New York, NY 10151
17. What is the difference between objecting and opting-out?
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 November 19, 2026, at 10:00am Eastern Time, at the Circuit Court for
Knox County, Tennessee, at 400 Main Street, Suite M30, Knoxville, TN 37902.
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 attorney’s fees and costs award and the request for Service Awards 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.SummitMedicalDataSettlement.com for updates.
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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.SummitMedicalDataSettlement.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-(866)-675-2936
• By mail: Summit 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, 400 Main
Street, Suite M30, Knoxville, TN 37902.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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