NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Steinle v. WPM Pathology Laboratory, and Salina Regional Health Center, Inc.
Case No. SA-2025-CV-000218
District Court of Saline County, Kansas
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE
NOVEMBER 2024 WPM PATHOLOGY LABORATORY AND SALINA REGIONAL
HEALTH CENTER, INC., DATA BREACH, 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 WPM Pathology Laboratory (“WPM Pathology”) and Salina
Regional Health Center, Inc. (together, “Defendants”) in a class action lawsuit. This case is about
the targeted cyberattack on WPM Pathology's computer systems that occurred in November 2024
(the “Data Breach”). Certain files that contained private information were accessed. These files may
have contained personal information such as dates of birth; Social Security numbers; diagnosis
information; medical record numbers; and health insurance claims information.
• The lawsuit is called Steinle v. WPM Pathology Laboratory, and Salina Regional Health Center, Inc.,
Case No. SA-2025-CV-000218. It is pending in the District Court of Saline County, Kansas (the
“Litigation”).
• Defendants deny that they 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.
• Defendants’ records indicate that you are a Class Member, and entitled to benefits under the
Settlement. You may have received a previous notice directly from WPM Pathology.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
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 19, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.WPMPLDataBreach.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 19, 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 19, 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 ................................................ 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 ...................................................................... 9
IF I DO NOTHING ........................................................................................................... 9
GETTING MORE INFORMATION ...................................................................................... 9
Basic Information
1. Why was this Notice issued?
The District Court of Saline 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 Steinle v. WPM Pathology Laboratory, and Salina Regional Health Center, Inc., Case No.
SA-2025-CV-000218. It is pending in the District Court of Saline County, Kansas. The person that filed this
lawsuit is called the “Plaintiff” (or “Class Representative”) and the companies they sued, WPM Pathology
Laboratory, and Salina Regional Health Center, Inc., are called the “Defendants.”
2. What is this lawsuit about?
This lawsuit alleges that during the November 2024 targeted cyberattack on WPM Pathology's computer
systems, certain files that contained private information were accessed. These files may have contained
personal information such as dates of birth; Social Security numbers; diagnosis information; medical record
numbers; and health insurance claims 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 Representative is Shawn Steinle. Everyone
included in this Action are the Class Members.
4. Why is there a Settlement?
The Court did not decide whether the Plaintiff 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 Plaintiff and their attorneys think the Settlement is best for all Class Members.
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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 whose Private Information was compromised in the Data
Breach, including all individuals to whom Defendants sent an individual notification letter to regarding the
Data Breach.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) WPM Pathology and its officers, directors, and related companies; (2)
governmental entities; (3) the Judge in this case, and the Judge’s family and staff; and (4) anyone who validly
excludes themselves from 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: 1-866-675-3062
• By mail: WPM Pathology Data Breach Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at www.WPMPLDataBreach.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Credit Monitoring and one or more of the cash payment options.
The benefits are explained in more detail below.
CREDIT MONITORING. All Class Members are eligible to enroll in two years of CyEx Identity Defense
Complete. This comprehensive service comes with $1 million in identity theft insurance, and includes:
• real time monitoring of your credit file
• dark web scanning
• comprehensive public records monitoring
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 Documented Ordinary Out-of-Pocket Expenses (out-of-pocket losses). If you
incurred actual, documented out-of-pocket expenses due to the Data Breach, you may receive
reimbursement up to $400.00. The losses must have occurred between November 4, 2024, and
October 19, 2026.
This benefit covers out-of-pocket expenses like:
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• fees for credit reports, credit monitoring, or freezing and unfreezing your credit
• cost to replace your IDs
• postage to contact banks by mail
You must send proof, like 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 Breach.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Reimbursement for Documented Extraordinary Out-of-Pocket Losses (losses from identity theft
or fraud). If you lost money because of identity theft or fraud, you may receive reimbursement up to
$4,000.00.
You will need to show that:
• the theft or fraud was more likely than not caused by the Data Breach
• the losses are not already covered by Ordinary Out-of-Pocket Expenses
• you tried to prevent the loss or get your money back, such as by using insurance you already
have
The losses must have occurred between November 4, 2024, and October 19, 2026.
You must send proof, like 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 Breach.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Reimbursement for Lost Time. Class Members who spent time responding to the Data Breach may
claim up to four hours, at $20.00 per hour, for a maximum of $80.00.
You must have spent the time on tasks related to the Data Breach. Some examples include things
like:
• changing your passwords
• investigating suspicious activity in your accounts
• researching the Data Breach
You must briefly describe how you spent this time.
Alternative Cash Payment. Instead of any other cash payment option, you may claim a one-time
cash payment of $45.00.
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: 1-866-675-3062
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Questions? Call 1-866-675-3062 Toll-Free or Visit www.WPMPLDataBreach.com
• By mail: WPM Pathology Data Breach 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 WPM Pathology and/or Salina
Regional Health Center, Inc., 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 Class. The
Settlement Agreement is available at www.WPMPLDataBreach.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.WPMPLDataBreach.com. If you prefer, you can
download a printable Claim Form from the website and mail it to the Settlement Administrator at:
WPM Pathology Data Breach 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,
1-866-675-3062, 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 19, 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 19, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on December 16, 2026 at 9:00AM (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 Grayson Wells of Stranch, Jennings & Garvey, PLLC and Richard Fisk
of Beam-Ward, Kruse, Wilson & Fletes, LLC., to represent you and other Class Members (“Class Counsel”).
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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 WPM Pathology.
Class Counsel will also ask for a Service Award Payment of $2,500.00 for the Class Representative. The
Service Award Payment will also be paid by WPM Pathology.
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 WPM Pathology
and/or Salina Regional Health Center, Inc., 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 October 19, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Litigation: Steinle v. WPM Pathology Laboratory, and Salina Regional Health Center,
Inc., Case No. SA-2025-CV-000218, pending in the District Court of Saline County, Kansas;
(2) your full name, mailing address, telephone number, and email address;
(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:
WPM Pathology Data Breach 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 19, 2026.
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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: Steinle v. WPM Pathology Laboratory, and Salina Regional Health
Center, Inc., Case No. SA-2025-CV-000218, pending in the District Court of Saline 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;
(5) if you or your lawyer have objected in any other cases in the past five years, list the names, courts,
the orders ruling on your objections, and civil action numbers for each of those cases;
(6) if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a
full list of both;
(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 October 19,
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 WPM Pathology Data Breach Settlement
300 W Ash Street ATTN: Objections
Salina, KS 67401 P.O. Box 25226
Santa Ana, CA 92799-9958
Class Counsel Counsel for Defendants
Grayson Wells Timothy Lowe
Stranch, Jennings & Garvey, PLLC McDonald Hopkins PLC
The Freedom Center 39533 Woodward Avenue, Suite 318
223 Rosa L. Parks Avenue, Suite 200 Bloomfield Hills, MI 48304
Nashville, TN 37203
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Justin Holmes
Richard Fisk Gordon Rees Scully Mansukhani LLP
Beam-Ward, Kruse, Wilson & Fletes, LLC Three Logan Square
8645 College Boulevard, Suite 250 1717 Arch Street, Suite 610
Overland Park, KS 66210 Philadelphia, PA 19103
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 December 16, 2026, at 9:00 A.M. Central Time, via Zoom and may be
accessed at the following address:
https://www.zoomgov.com/my/judgepeterson311
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 a Service Award Payment to the Class
Representative. 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.WPMPLDataBreach.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.
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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.WPMPLDataBreach.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: 1-866-675-3062
• By mail: WPM Pathology Data Breach 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, 300 W Ash
Street Salina, KS 67401.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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