NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
In Re: Susan B. Allen Data Security Litigation
Case No. BU-2025-CV-000185
District Court of Butler County, Kansas
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE JULY 2025
SUSAN B. ALLEN MEMORIAL HOSPITAL 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 Susan B. Allen Memorial Hospital (“SBAMH” or “Defendant”) in
a class action lawsuit. This case is about the targeted cyberattack on SBAMH's computer systems
that occurred in July 2025 (the “Data Incident”). Certain files that contained private information were
accessed. These files may have contained personal information such as names, dates of birth,
health insurance information, billing information, and medical treatment information.
• The lawsuit is called In Re: Susan B. Allen Data Security Litigation, Case No. BU-2025-CV-000185. It
is pending in the District Court of Butler County, Kansas (the “Litigation”).
• SBAMH 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.
• SBAMH'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 SBAMH.
• 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 12, 2026
is by submitting a valid and timely Claim Form.
The most efficient way to submit your Claim Form is online at
www.SBAMHDataSettlement.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 October 13, 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 October 13, 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 ................................................ 5
THE LAWYERS REPRESENTING YOU ............................................................................... 6
EXCLUDING YOURSELF FROM THE SETTLEMENT ............................................................ 6
COMMENTING ON OR OBJECTING TO THE SETTLEMENT.................................................. 7
THE COURT’S FINAL APPROVAL HEARING ...................................................................... 8
IF I DO NOTHING ........................................................................................................... 8
GETTING MORE INFORMATION ...................................................................................... 9
Basic Information
1. Why was this Notice issued?
The District Court of Butler County, Kansas, 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: Susan B. Allen Data Security Litigation, Case No. BU-2025-CV-000185. It is pending
in the District Court of Butler County, Kansas. The people that filed this lawsuit are called the “Plaintiffs” (or
“Class Representatives”) and the company they sued, Susan B. Allen Memorial Hospital, is called the
“Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the July 2025 targeted cyberattack on SBAMH’s computer systems, certain
files that contained private information were accessed. These files may have contained personal information
such as names, dates of birth, health insurance information, billing information, and medical treatment
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 Dean Dickhout, Jessica
Huston, Robin Kiddoo, and Brenda Sherman. Everyone included in this Action are the Class Members.
4. Why is there a Settlement?
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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 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 Class this way: “All persons who were sent written notification of the Data
Incident.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) the Judge in this case, and the Judge’s family and staff; and (2) anyone
who perpetrated the Data Incident.
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) 421-7273
• By mail: SBAMH 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.SBAMHDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Credit Monitoring and Identity Theft Protection Services and
one or more of the cash payment options. The benefits are explained in more detail below.
CREDIT MONITORING AND IDENTITY THEFT PROTECTION SERVICES. 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.
CASH PAYMENT OPTIONS
Reimbursement for Out-of-Pocket Losses. If you incurred actual, documented out-of-pocket losses
due to the Data Incident, you can get back up to $100.00. The losses must have occurred between
July 14, 2025, and November 12, 2026.
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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.
Reimbursement for Attested Time. Settlement Class Members who spent time responding to the
Data Incident may claim up to four hours, at $25.00 per hour, for a maximum of $100.00.
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 briefly describe how you spent this time.
There is an aggreagate cap of $100.00 on these benefits. This means that the total amount you can receive
for both types of cash claims is subject to to a $100.00 aggregate cap.
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) 421-7273
• By mail: SBAMH 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 Settlement Class?
If you stay in the Settlement Class, you won’t be able to be part of any other lawsuit against SBAMH about the
issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section IV)
describes the legal claims that you give up if you remain in the Settlement Class. The Settlement Agreement
is available at www.SBAMHDataSettlement.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.SBAMHDataSettlement.com. If you prefer, you
can download a printable Claim Form from the website and mail it to the Settlement Administrator at:
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Questions? Call 1-(833) 421-7273 toll-free or visit www.SBAMHDataSettlement.com
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SBAMH 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) 421-7273, 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 12, 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 12, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on December 7, 2026, at 9:00 am CT (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 law firms Milberg, PLLC and McShane & Brady, LLC to represent you and the
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 $150,000.00 as reasonable attorneys' fees and costs of
Litigation. This amount will be paid by SBAMH.
Class Counsel will also ask for Service Award payments of $1,500.00 for each of the Class Representatives.
Service Award payments will also be paid by SBAMH.
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 SBAMH on your own
about the legal issues in this case.
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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 13, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: In Re: Susan B. Allen Data Security Litigation, Case No. BU-2025-CV-
000185, pending in the District Court of Butler County, Kansas;
(2) your full name, mailing address, telephone number, and email address;
(3) the words “Request for Exclusion” at the top of the document;
(4) a declaration stating “I request that I be excluded from the Settlement Class and do not wish to
participate in the settlement. I understand that by requesting to be excluded from the Settlement
Class, I will not receive any benefits under the Settlement.” and
(5) personal signature.
You may only exclude yourself—not any other person.
Mail your Request for Exclusion to the Settlement Administrator at:
SBAMH 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 October 13, 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 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: Susan B. Allen Data Security Litigation, Case No. BU-2025-CV-
000185, pending in the District Court of Butler County, Kansas;
(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; and
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(5) your signature (or, if you have hired your own lawyer, your lawyer’s signature).
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 13,
2026. You must also send a copy of the objection to the Settlement Administrator.
Clerk of the Court Settlement Administrator
Clerk of the Court SBAMH Data Incident Settlement
Butler County Courthouse ATTN: Objections
205 W. Central Ave. P.O. Box 25226
El Dorado, KS 67042 Santa Ana, CA 92799-9958
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 December 7, 2026, at 9:00 am Central Time via Zoom video
conference.
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 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.SBAMHDataSettlement.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?
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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.SBAMHDataSettlement.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) 421-7273
• By mail: SBAMH 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, District Court
of Butler County, Kansas at 205 W. Central Ave., El Dorado, KS 67402.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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