NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
In re Tift Regional Health System, Inc. Data Breach Litigation
Case No. 2023CV0313
Superior Court for Tift County, Georgia
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE AUGUST 2022
TIFT REGIONAL HEALTH SYSTEM, INC. AND SOUTHWELL, INC.,
DATA SECURITY 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 Tift Regional Health System, Inc. and Southwell, Inc. (“Tift”
or “Defendants”) in a class action lawsuit. This case is about the targeted cyberattack on Tift's
computer systems that occurred in August 2022 (the “Data Security Incident”). Certain files that
contained private information were accessed. These files may have contained personal information
such as names; dates of birth; Social Security numbers; and medical information.
• The lawsuit is called In re Tift Regional Health System, Inc. Data Breach Litigation, Case No.
2023CV0313. It is pending in the Superior Court for Tift County, Georgia (the “Litigation”).
• Tift 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.
• Tift'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 Tift.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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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 15, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.TiftDataSettlement.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 15, 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 September 15, 2026
SETTLEMENT writing to the Court about why you don’t like the Settlement. You
may also ask the Court for permission to speak about your
AND/OR ATTEND A objection at the Final Approval Hearing. If you object, you may
HEARING also file a claim for Settlement benefits.
DO NOTHING Unless you opt out of the Settlement, you are automatically part No Deadline
of 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 ..........................................................................................................................9
GETTING MORE INFORMATION ...............................................................................................9
Basic Information
1. Why was this Notice issued?
The Superior Court for Tift County, Georgia, 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 Tift Regional Health System, Inc. Data Breach Litigation, Case No.
2023CV0313. It is pending in the Superior Court for Tift County, Georgia. The people that filed this lawsuit
are called the “Plaintiffs” (or “Class Representatives”) and the companies they sued, Tift Regional Health
System, Inc. and Southwell, Inc., are called the “Defendants.”
2. What is this lawsuit about?
This lawsuit alleges that during the August 2022 targeted cyberattack on Tift's computer systems, certain
files that contained private information were accessed. These files may have contained personal information
such as names; dates of birth; Social Security numbers; and medical 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 Chaka
Davis; Brooke Dobbins; Janice Farley; and Zoie Walsh. Everyone included in this Lawsuit are the Class
Members.
4. Why is there a Settlement?
The Court did not decide whether the Plaintiffs or the Defendants 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?
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5. Who is included in the Settlement?
The Court has defined the Class this way: “All individuals residing in the United States whose Private
Information may have been compromised or otherwise impacted in the Data Security Incident, including
all those who received notice of the breach.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) the Judge(s) presiding over the Litigation, and the Judge’s immediate
family and staff; (2) Tift and its officers, directors, related companies, successors, predecessors, and any
entity in which Tift has a controlling interest; (3) anyone who validly excludes themselves from the
Settlement; and (4) the successors or assigns of any such excluded natural person.
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) 421-7345
• By mail: Tift Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at www.TiftDataSettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
Tift will establish a Settlement Fund of $1,200,000.00. The Settlement Fund will first be used to pay
court-approved attorneys’ fees and costs, Service Award payments for the Plaintiffs, and the costs of
administering the Settlement. The net remaining money will be used to pay for the benefits described
below.
All Class Members are eligible to enroll in Credit Monitoring Services and one of two cash payment
options. These benefits are described in more detail below.
CREDIT MONITORING SERVICES. All 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
Documented Loss Payment. If you incurred actual, documented out-of-pocket losses due to the
Data Security Incident, you can get back up to $5,000.00. The losses must have occurred between
August 11, 2022, and October 15, 2026.
This benefit covers out-of-pocket expenses like:
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• 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 Security Incident.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Alternative Cash Payment. Instead of the Documented Loss Payment, you may claim a one-time
pro rata cash payment.
It is expected that a significant amount of money will remain in the Settlement Fund after all
expenses and all other benefits have been paid. All of this remaining money will be divided equally
between everyone who claims an Alternative Cash Payment.
This payment is expected to be $75.00, but may be larger or smaller depending on the total claims
filed. 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) 421-7345
• By mail: Tift Data Security 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 Tift about the issues that
this Settlement covers. The “Releases” section of the Settlement Agreement (Section 4) describes the legal
claims that you give up if you remain in the Class. The Settlement Agreement is available at
www.TiftDataSettlement.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.TiftDataSettlement.com. If you prefer, you
can download a printable Claim Form from the website and mail it to the Settlement Administrator at:
Tift Data Security 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) 421-7345, by email [email protected], or by U.S. mail at the address above.
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10. Are there any important Settlement payment deadlines?
If you are submitting a Claim Form online, you must do so by October 15, 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 15, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on September 14, 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 Gary Mason of Mason LLP; William B. Federman of Federman &
Sherwood; Bryan L. Bleichner of Chestnut Cambronne PA; and Kevin Laukaitis of Laukaitis Law 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 $360,000.00 as reasonable attorneys' fees, plus reimbursement
of litigation costs. This amount will be paid from the Settlement Fund.
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 from the Settlement Fund.
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 Tift 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.
The deadline to exclude yourself from the Settlement is September 15, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: In re Tift Regional Health System, Inc. Data Breach Litigation, Case
No. 2023CV0313, pending in the Superior Court for Tift County, Georgia;
(2) your full name, mailing address, telephone number, and email address;
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(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:
Tift Data Security 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 September 15, 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:
(1) the name of the Litigation: In re Tift Regional Health System, Inc. Data Breach Litigation, Case
No. 2023CV0313, pending in the Superior Court for Tift County, Georgia;
(2) your full name, mailing address, telephone number, and email address;
(3) information that proves that you are a Class Member (such as a notice you have received);
(4) a clear description of all the reasons you object; include any legal support, such as documents,
you may have for your objection;
(5) if you have hired your own lawyer to represent you for this objection, provide their name, bar
number, and contact information;
(6) if you or your lawyer have objected in any other cases in the past five years, list the names,
courts, and civil action numbers for each of those cases;
(7) whether or not you or your lawyer would like to speak 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 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
15, 2026. You must also send a copy of the objection to the Settlement Administrator.
Clerk of the Court Settlement Administrator
Clerk of the Court Tift Data Security Incident Settlement
237 E 2nd St ATTN: Objections
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Tifton, GA 31794 P.O. Box 25226
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 on September 14, 2026 at 10:00 a.m. Eastern Time, at the Superior
Court for Tift County, Georgia, 237 E 2nd St, Tifton, GA 31794.
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
www.TiftDataSettlement.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.TiftDataSettlement.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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• Call toll free, 24/7: 1-(833) 421-7345
• By mail: Tift Data Security 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, 237 E
2nd St, Tifton, GA 31794.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS
SETTLEMENT
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