Natasha Hiller v. The Money Source, Inc.
United States District Court for the District of Arizona
Case No. CV-23-00235-PHX-JJT
This is a notice of a settlement of a class action lawsuit.
This is NOT a notice of a lawsuit against you.
You are NOT being sued.
If you were called on your cellular telephone between February 6, 2019 through May 7, 2025 by The Money
Source, Inc. (“TMS” or “Defendant”) with a prerecorded voice after you asked TMS to stop calling you,
you may be entitled to a cash payment as a result of the settlement in the above class action lawsuit.
Receiving notice of this class action, however, does not necessarily mean that you are a class member or
that you are entitled to compensation. Only persons who fit within the definition of the Settlement Class
can receive money from the Settlement Fund.
A federal court authorized this Notice. This is not a solicitation from a lawyer.
Please read this Notice carefully.
It explains your rights and options to potentially participate in the class action settlement.
• The Action: Natasha Hiller (“Plaintiff”) filed a Class Action Complaint against TMS, asserting
claims under the Telephone Consumer Protection Act (“TCPA”). Plaintiff alleges that she and members of
the Class received prerecorded and/or artificial voice telephone calls from Defendant after they asked TMS
to stop calling. Defendant denies Plaintiff’s allegations. Defendant further asserts that it acted in good faith
to comply with all relevant laws. The Court has not ruled on the merits of Plaintiff’s claims or Defendant’s
defenses. Defendant has agreed to enter into the Settlement, and by doing so has not conceded the truth or
validity of any of the claims against it.
• The Class Definition: All persons throughout the United States or its territories (1) to whom
Defendant placed, or caused to be placed, a call, (2) directed to a number assigned to a cellular telephone
service , (3) in connection with which Defendant used an artificial or prerecorded voice, (4) after the called
party requested that Defendant stop placing telephone calls using an artificial or prerecorded voice to their
cellular telephone, as recorded in Defendant’s business records, (5) from February 6, 2019 through May 7,
2025.
• The Settlement: TMS will establish a Settlement Fund of $1,500,000.00 to fully settle and release
claims of persons to whom TMS placed, or caused to be placed, a call, directed to a number assigned to a
cellular telephone service and that appears on the document produced at TMS005442, in connection with
which Defendant used an artificial or prerecorded voice, after the called party requested that Defendant stop
placing telephone calls using an artificial or prerecorded voice to their cellular telephone, as recorded in
Defendant’s business records from February 6, 2019 through May 7, 2025.
• Your rights and options, and the deadlines to exercise them, are explained more fully in this Notice.
Your legal rights are affected whether you act or don’t act. Read this Notice carefully. Some of your
rights include:
o Your Right to Hire an Attorney: The Court has appointed Plaintiff’s attorneys to act as class
counsel. You do not have to pay class counsel. Any Class Member may enter an appearance in
this lawsuit through an attorney if the member so desires. You are not required to hire any
attorney, however, to exercise your rights, but if you do want to be represented by your own
lawyer, you must hire one at your own expense.
o How to Exclude Yourself: To exclude yourself, you must request an exclusion. To be valid, you
must mail a written notice of exclusion to the Administrator, so that it is postmarked no later
than October 7, 2026 (the “Exclusion Request Deadline”). To exclude yourself, follow the
procedures described under Question 13 below.
o The Binding Effect of a Class Judgment: Unless you exclude yourself, the Court will find you
have agreed to the Settlement, and you will be part of the Settlement Class and will be bound by
the release of claims in the Settlement. This means that if the Settlement is approved, you cannot
pursue or continue to pursue any Released Claim, as explained more fully below, against
Defendant or any other Released Parties, whether on your own or as part of any other lawsuit.
It also means that all of the Court’s orders will apply to you and legally bind you. In summary,
unless you exclude yourself, the Court will find you have agreed to release Defendant and any
other Released Parties, as defined in the Class Action Settlement Agreement, from any and all
claims that were asserted in the litigation and all claims that relate to or arise from Defendant
placing telephone calls with prerecorded messages and/or artificial voice.
o The Final Approval Hearing: The Court will hold a Final Approval Hearing on November 16,
2026 at 2:00 PM (Arizona time) in Room 505 in the United States District Court for the District
of Arizona, United States District Court District of Arizona - Phoenix Division, Sandra Day
O'Connor U.S. Courthouse, 401 West Washington Street, Phoenix, AZ 85003-2118. At this
hearing, the Court must still decide whether the Settlement is fair, reasonable and adequate.
o Exclusion Deadline / Bar Date: If you do not opt-out or exclude yourself from the Settlement
by October 7, 2026, you will receive a payment and will give up your rights to pursue or
continue to pursue a Released Claim. To exclude yourself, follow the procedures described
under Question 13 below.
o The Court in charge of this case must still decide whether to approve the Settlement. Payments
will be made if the Court approves the Settlement and after any appeals are resolved. Please be
patient.
Class Counsel Contact Information Defendant Counsel Contact Information
Max S Morgan, Esq. Eric E. Lynch
The Weitz Firm, LLC Polsinelli PC
1515 Market St., #1100 One E. Washington Street, Suite 1200
Philadelphia, PA 19102 Phoenix, AZ 85004
E-mail: [email protected]
Administrator Contact Information
Chris R. Miltenberger The Money Source TCPA Class Action
Law Office of Chris R. Miltenberger, PLLC c/o Atticus Administration
1360 N. White Chapel, Suite 200 PO Box 64053
Southlake, Texas 76092 St. Paul, MN 55164
E-mail: [email protected] Toll Free: 1-800-679-0774
www.MoneySourceTCPAClassAction.com
SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS
If you stay in the Settlement and do not opt-out, you will receive a
monetary award if your membership in the class is confirmed and
STAY IN THE you will give up your rights to pursue or continue to pursue a
SETTLEMENT Released Claim against Defendant and/or any other Released Parties.
You may need to provide the Administrator with your taxpayer
identification number, or you may be subject to backup withholding.
If you ask to be excluded, you will not receive a payment. This is the
EXCLUDE YOURSELF
only option that allows you to pursue or continue to pursue a
OR “OPT-OUT” OF THE
SETTLEMENT Released Claim against Defendant and/or other Released Parties on
your own. The deadline for excluding yourself is October 7, 2026.
You may write to the Court about why you believe the Settlement is
unfair in any respect, including any requested amounts of attorneys’ fees
or expenses. The deadline for objecting is October 7, 2026. If you
OBJECT TO THE
object but do not exclude yourself, you are still part of the Settlement
SETTLEMENT
Class and will receive a payment. If you do not exclude yourself, you
will give up your rights to pursue or continue to pursue a Released
Claim against Defendant and/or any other Released Parties.
BASIC INFORMATION
1. What is the purpose of this Notice?
The purpose of this Notice is to inform you that a proposed Settlement has been reached in the class action
lawsuit captioned Natasha Hiller v. The Money Source, Inc., Case No. 2:23-cv-00235-PHX-JJT (D.
Arizona). Because your rights will be affected by this Settlement, it is extremely important that you read
this Notice carefully. This Notice summarizes the Settlement and your rights under it.
2. What does it mean if I received a letter or e-mail about this Settlement?
If you received a letter or e-mail describing this Settlement, it is because Defendant’s records indicate that
you may be a member of the Settlement Class in this action. The Settlement Class is defined in Question 5
below.
3. What is this class action lawsuit about?
In a class action, one or more people called Class Representative(s) (here, Plaintiff) sue on behalf of people
who allegedly have similar claims. This group is called a class and the persons included are called
Settlement Class Members. One court resolves the issues for all of the Settlement Class Members, except
for those who exclude themselves from the class.
Here, Natasha Hiller alleges that she and members of the class received prerecorded and/or artificial voice
telephone calls on their cellular telephone numbers from Defendant after requesting that Defendant stop
placing telephone calls using an artificial or prerecorded voice to their cellular telephones from February 6,
2019 through May 7, 2025. Defendant denies Plaintiff’s allegations that the calls were unlawful
whatsoever. Defendant further asserts that Defendant acted in good faith to comply with all relevant laws.
The Court has not ruled on the merits of Plaintiff’s claims or Defendant’s defenses. Defendant has agreed
to enter into the Settlement, and by doing so has not conceded the truth or validity of any of the claims
against it.
The Court has conditionally certified a class action for settlement purposes only. The Honorable John J.
Tuchi is the judge in charge of the lawsuit.
4. Why is there a Settlement?
The Court did not decide in favor of Plaintiff or Defendant. Instead, both sides agreed to this Settlement.
That way, they avoid the risk and cost of further litigation and a potential trial, and the Settlement Class
Members will receive compensation. Plaintiff and Class Counsel think the Settlement is best for all
Settlement Class Members.
WHO IS IN THE SETTLEMENT CLASS?
5. How do I know if I am part of the Settlement Class?
The Court has certified this case as a class action for settlement purposes only. The Settlement Class
includes:
All persons throughout the United States or its territories (1) to whom Defendant placed, or
caused to be placed, a call, (2) directed to a number assigned to a cellular telephone service
and that appears on the document produced at TMS005442, (3) in connection with which
Defendant used an artificial or prerecorded voice, (4) after the called party requested that
Defendant stop placing telephone calls using an artificial or prerecorded voice to their
cellular telephone, as recorded in Defendant’s business records, (5) from February 6, 2019
through May 7, 2025.
Notwithstanding the foregoing, the Settlement Class specifically excludes persons in the following
categories: (A) Defendant and their employees and agents; (B) members of the judiciary; and (C) all persons
who file a timely and proper request to be excluded from the Settlement Class in accordance with the Class
Action Settlement Agreement.
If you are still not sure whether you are included in the Class Action Settlement Class, you can visit other
sections of the Settlement Website, www.MoneySourceTCPAClassAction.com or you may write to or call
the Administrator for more information:
THE MONEY SOURCE, INC., SETTLEMENT ADMINISTRATOR
C/O ATTICUS ADMINISTRATION
PO BOX 64053
SAINT PAUL MN 55164
1-800-679-0774
[email protected]
THE LAWYERS REPRESENTING YOU
6. Do I have lawyers in this case?
The Court has appointed lawyers from the law firms of The Weitz Firm, LLC and Law Office of Chris R.
Miltenberger, PLLC as Class Counsel to represent you and the other persons in the Settlement Class. You
will not be personally charged by these lawyers.
7. How will Class Counsel be paid?
Class Counsel will ask the Court to approve payment of up to one-third (1/3) of the settlement fund to them
for attorneys’ fees, plus the costs and expenses incurred litigating the claims in this matter, subject to the
Court’s approval.
THE SETTLEMENT BENEFITS – WHAT YOU GET
8. What does the settlement provide?
Settlement Fund. Defendant has agreed to pay $1,500,000.00 to cover: (1) payments to Settlement Class
Members; (2) all reasonable costs, fees and any other charges invoiced by the Administrator, including the
cost of notice to potential Settlement Class Members, the cost of any publication notice, and claims
administration for the Settlement Class; (3) litigation costs and expenses not to exceed $17,000.00, for
which Class Counsel will petition the Court; (4) reasonable attorneys’ fees, calculated as a percentage of
the Settlement Fund, for which Class Counsel will petition the Court; and (5) incentive awards to Plaintiff,
for which Plaintiff will petition the Court.
Payments. A pro rata payment from the Settlement Fund will be made to all Settlement Class Members.
In order to comply with applicable tax reporting requirements, Settlement Payments may be subject to IRS
reporting. Class Members may be required to provide a valid taxpayer identification number (e.g., via IRS
Form W-9). Please complete and return a W-9 form to the Administrator. You can download the form
HERE. You can return the form by e-mail to: [email protected], by
faxing it to: 1-888-326-6411, or by mailing it to the following address: The Money Source Settlement
Administrator, PO Box 64053, St. Paul, MN 55164.
If a Class Member does not provide the required information, the Settlement Administrator will apply
“backup withholding” at the rate prescribed by the IRS (currently 24%) and remit that amount to the IRS.
Any amount withheld will be reported to the Class Member and may be claimed as a credit or refund, if
applicable, when the Class Member files their federal income tax return. If you have questions about how
this may affect you, you are encouraged to consult a tax advisor.
9. How much will my payment be?
Settlement Class Members will receive a pro rata payment from the Settlement Fund, based on the number
of calls such Settlement Class Member received after requesting that Defendant stop placing telephone calls
using an artificial or prerecorded voice to their cellular telephone, as recorded in Defendant’s business
records, after deducting: (i) costs and expenses of administering the Settlement; (ii) Class Counsel’s
attorneys’ fees awarded by the Court; (iii) Class Counsel’s costs and expenses awarded by the Court; and
(iv) the service award to Plaintiff approved by the Court.
10. What am I giving up to stay in the Settlement Class?
You are giving up your right to legally pursue the Released Claims, as defined in the Class Action Settlement
Agreement. This means that if the Settlement is approved, you cannot pursue or continue to pursue any
Released Claim against Defendant or any other Released Parties, whether on your own or as part of any
other lawsuit, as explained in the Class Action Settlement Agreement. It also means that all of the Court’s
orders will apply to you and legally bind you. Unless you exclude yourself from the Settlement, the Court
will find you have agreed to be part of the Settlement Class and have agreed to release Defendant and any
other Released Parties, as defined in the Settlement Agreement and Release, from any and all claims that
were asserted in the litigation and all claims that relate to or arise from Defendant placing telephone calls
with prerecorded messages or artificial voice to you.
In summary, the Released Claims include, without limitation, all claims that were asserted or could have
been asserted in the litigation based on Defendant allegedly placing telephone calls with prerecorded
messages and/or artificial voice without consent, including, but not limited to, claims under the TCPA or
any other statute or the common law, for any form of relief.
If you have any questions about the release or what it means, you can speak to Class Counsel, listed under
Question 6, for free, or you can, at your own expense, talk to your own lawyer. The release does not apply
to persons in the Settlement Class who timely exclude themselves.
HOW TO OBTAIN A PAYMENT
11. How can I get a payment?
A notice has been sent by U.S. Mail and e-mail to all persons who have been identified as Settlement Class
Members based on Defendant’s records. All Settlement Class Members who do not submit timely exclusion
requests will be sent a Settlement Payment. If you are entitled to an amount greater than $2,000, you must
first provide the Settlement Administrator with your taxpayer identification number or you may be subject
to backup withholding.
WHEN WILL I RECEIVE MY SETTLEMENT PAYMENT?
12. When will I receive a Settlement payment?
The Court will hold a Final Approval Hearing to decide whether to approve the Settlement. If the Court
approves the Settlement, after that, there may be appeals. If there are appeals, it is uncertain when they will
conclude, but resolving them can take time, perhaps more than a year. Everyone that does not submit a
timely exclusion request will be informed of the progress of the Settlement through information posted on
the Settlement Website at www.MoneySourceTCPAClassAction.com. Please be patient.
EXCLUDING YOURSELF FROM THE SETTLEMENT
13. How can I get out of (i.e., opt-out of or exclude myself from) the Settlement?
If you want to keep your rights to pursue or continue to pursue any Released Claim against Defendant and/or
any Released Parties, as defined in the Settlement Agreement and Release, then you must take steps to get
out of the Settlement Class. This is called excluding yourself from, or opting-out of, the Settlement Class.
If you exclude yourself, you will not be legally bound by anything that happens in this lawsuit and will not
receive a payment.
To exclude yourself from the Settlement, you must submit an exclusion request by mail to the Administrator
at:
THE MONEY SOURCE, INC., SETTLEMENT ADMINISTRATOR
C/O ATTICUS ADMINISTRATION
PO BOX 64053
ST. PAUL, MN 55164
The exclusion request must be postmarked by October 7, 2026.
To be valid, your exclusion form must be postmarked no later than October 7, 2026 (the “Opt-Out
Deadline”), and shall clearly state the following in the written notice of exclusion: (a) identify the case
name; (b) identify the full name, mailing address, and telephone number of the Class Member requesting
exclusion; (c) identify the cellular telephone number(s) where the Class Member received a pre-recorded
voice telephone call from Defendant relating to the litigation; (d) contain the statement that indicates a desire
to be excluded from the Settlement Class in the litigation, such as “I hereby request that I be excluded from
the proposed Settlement Class in Natasha Hiller v. The Money Source, Inc., Case No. 2:23-cv-00235-PHX-
JJT (D. Arizona)”; and (e) be personally signed by the Settlement Class Member requesting exclusion. No
request for exclusion will be valid unless all of the information described above is included. No person in
the Settlement Class, or any person acting on behalf of or in concert or participation with that person in the
Settlement Class, may exclude any other person in the Settlement Class from the Settlement Class.
Class, combined, joint, collective, or group opt-outs or exclusions shall be prohibited.
To be valid, your exclusion request must be postmarked no later than October 7, 2026 to the
Administrator at The Money Source, Inc., Settlement Administrator, c/o Atticus Administration, PO
BOX 64053, St. Paul, MN 55164.
14. If I do not exclude myself, can I sue Defendant for the same thing?
No. If you do not exclude yourself, you give up any rights to pursue (or continue to pursue) any Released
Claims against Defendant and/or any Released Parties.
15. If I exclude myself, can I get a benefit from this Settlement?
No. If you ask to be excluded, you will not receive a Settlement payment, and you cannot object to the
Settlement.
OBJECTING TO THE SETTLEMENT
16. How do I tell the Court that I do not think the Settlement is fair?
If you are in the Settlement Class, you can object to the Settlement or any part of the Settlement that you
think the Court should reject, and the Court will consider your views. If you do not provide a written
objection in the manner described below, you shall be deemed to have waived any objection and shall
forever be foreclosed from making any objection to the fairness, reasonableness, or adequacy of the
Settlement or the award of any attorneys’ fees, costs, and expenses.
To be valid, the written objection must include: (a) the case name and number of the litigation; (b) the full
name, address, and telephone number of the Settlement Class Member objecting and, if represented by
counsel, of his/her counsel with counsel’s contact information; (c) the cellular telephone number(s) where
he/she received pre-recorded voice telephone calls from Defendant relating to the litigation; (d) a statement
that the person objecting is a Class Member; (e) a statement of each objection, including the specific
reasons, if any, for each objection, including any legal and factual support the objector wishes to bring to
the Court’s attention and any evidence the objector wishes to introduce in support of the objection(s); (f) a
statement of whether he/she intends to appear at the Final Approval Hearing, either with or without counsel;
and (g) the objector’s signature.
Class, combined, joint, collective or group objections shall be prohibited.
Any Settlement Class Member who fails to object to the Settlement in the manner described above shall be
deemed to have waived any such objection, shall not be permitted to object to any terms or approval of the
Settlement at the Final Approval Hearing, and shall be foreclosed from seeking any review of the Settlement
or the terms of the Settlement Agreement by appeal or other means.
To be considered, you must file your objections with the Court, or mail to the Court at the address
below and be postmarked no later than October 7, 2026:
Clerk of Court
United States District Court District of Arizona - Phoenix Division
Sandra Day O'Connor U.S. Courthouse, Suite 130
401 West Washington Street, SPC 1
Phoenix, AZ 85003-2118
Attention: Natasha Hiller v. The Money Source, Inc., No. 2:23-cv-00235-PHX-JJT (D. Ariz)
Your objections must also be mailed to the addresses below and postmarked no later than October
7, 2026.
For Plaintiff: For Defendant:
Max S. Morgan, Esq. Eric E. Lynch, Esq.
The Weitz Firm, LLC Polsinelli PC
1515 Market Street #1100 One E. Washington Street, Suite 1200
Philadelphia, PA 19102 Phoenix, AZ 85004
If you file an objection, you will still obtain a benefit from this Settlement, unless you exclude
yourself from the Settlement.
17. What is the difference between objecting and excluding yourself?
Objecting is telling the Court that you oppose something about the Settlement. You can object only if you
stay in the Settlement Class. Excluding yourself means that you do not want to be part of the Settlement
Class. If you exclude yourself, you have no basis to object because the case no longer affects you.
IF YOU DO NOTHING
18. What happens if I do nothing at all?
If you do nothing, you will receive a monetary award and you will give up your rights to pursue or continue
to pursue Released Claims against Defendant and/or any other Released Parties. For information relating
to what rights you are giving up, see Question 10.
THE FINAL APPROVAL HEARING
19. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Final Approval Hearing on November 16, 2026 at 2:00 PM (Arizona time) in Room
505 in the United States District Court for the District of Arizona, United States District Court District of
Arizona - Phoenix Division, Sandra Day O'Connor U.S. Courthouse, 401 West Washington Street, Phoenix,
AZ 85003-2118. At this hearing, the Court will consider whether the Settlement is fair, reasonable and
adequate. If there are valid objections that comply with the requirements in Question 16 above, the Court
will also consider them and will listen to people who have asked to speak at the hearing. The Court will
also decide how much to pay to Class Counsel.
The Final Approval Hearing may be moved to a different date or time without additional mailed notice, so
please check the Settlement Website for updates.
20. Do I have to come to the hearing?
No. Class Counsel will appear on behalf of the Settlement Class. But, you are welcome to come, or have
your own lawyer appear, at your own expense.
21. May I speak at the hearing?
You may ask the Court for permission to speak at the Final Approval Hearing, but only in connection with
an objection that you have timely submitted to the Court according to the procedure set forth in Question
16 above. To speak at the Final Approval Hearing, you must also file a document with the Court stating
your intention to appear. For this document to be considered, it must include: (a) the case name and number
of the litigation; (b) the Settlement Class Member’s full name, address, telephone number, and signature,
and, if represented by counsel, their contact information; (c) the cellular telephone number(s) where he/she
received a pre-recorded telephone call from Defendant relating to the litigation; (d) copies of any papers,
exhibits, or other evidence that the objecting Settlement Class Member will present to the Court in
connection with the Final Approval Hearing; and (e) identify any witnesses that the Settlement Class
Member intends to call. The document must be filed with the Court no later than October 7, 2026. You
cannot speak at the hearing if you exclude yourself from the Settlement.
To be considered, you must file your Notice of Intention to Appear with the Court by mailing to the
address below and postmarked no later than October 7, 2026:
Clerk of Court
United States District Court District of Arizona - Phoenix Division
Sandra Day O'Connor U.S. Courthouse, Suite 130
401 West Washington Street, SPC 1
Phoenix, AZ 85003-2118
Attention: Natasha Hiller v. The Money Source, Inc., No. 2:23-cv-00235-PHX-JJT (D. Ariz)
GETTING MORE INFORMATION
22. How do I get more information?
This Notice is only a summary of the proposed Settlement. You can get a complete copy of the Settlement
Agreement and other material documents by visiting the Settlement Website,
www.MoneySourceTCPAClassAction.com, or you can write to the Settlement Administrator at the address
below or call the Toll-Free Settlement Hotline, 1-800-679-0774.
The Money Source TCPA Class Action
c/o Atticus Administration
PO Box 64053
St. Paul, MN 55164
DO NOT CALL OR WRITE TO THE COURT, THE CLERK OF THE COURT, DEFENDANT,
OR DEFENDANT’S COUNSEL ABOUT THE SETTLEMENT. ALSO, TELEPHONE
REPRESENTATIVES WHO ANSWER CALLS MADE TO THE TOLL-FREE NUMBER ARE
NOT AUTHORIZED TO CHANGE THE TERMS OF THE SETTLEMENT OR THIS NOTICE.
