NOTICE OF CLASS ACTION AND PROPOSED SETTLEMENT

If you were notified of a Data Security Incident occurring on or

around March 30, 2023 involving Henry Ford Health System, you
may be entitled to benefits from a settlement.
A federal court has authorized this Notice.
This is not a solicitation from a lawyer.

 A proposed settlement has been reached in a class action lawsuit known as In re Henry Ford
Health System Data Security Litigation, Case No. 2:23-cv-11736, filed in the United States
District Court for the Eastern District of Michigan.

 This Lawsuit arises out of a targeted cybersecurity attack on Henry Ford’s network and
computer systems (the “Data Security Incident”), which occurred on or about March 30,
2023 and potentially resulted in unauthorized access to names, genders, dates of birth, ages,
lab results, procedure types, diagnoses, dates of service, telephone numbers, medical record
numbers and/or internal tracking numbers (the “Personal Information”) of Settlement Class
Members. Henry Ford disagrees with Plaintiffs’ claims and denies any wrongdoing.

 You are a “Settlement Class Member” if you reside in the United States and were mailed a notice
letter by Henry Ford notifying you that your Personal Information was potentially accessed,
viewed, and/or obtained in the Data Security Incident that occurred on or around March 30, 2023.

 Settlement Class Members can submit a Claim Form for the following:

Credit Monitoring and Insurance Services (“CMIS”): One (1) year of two-credit bureau
credit monitoring and $1 million in identity theft insurance, irrespective of whether they took
advantage of any previous offering of credit monitoring from Henry Ford; and

1. Documented Loss Payment: Reimbursement of up to $2,500 in the form of a

Documented Loss Payment related to the Data Security Incident;

-OR-

2. Cash Fund Payment: A pro rata Settlement Payment in cash (“Cash Fund Payment”).

Your legal rights are affected regardless of whether you do

or do not act. Read this notice carefully.

Your Legal Rights and Options Deadline

To get Settlement benefits for Credit Monitoring and
Submit a Insurance Services and Documented Loss payment or a October 28, 2024
Claim Form Cash Fund Payment, you must submit a Claim Form.

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Exclude Get out of the settlement. Get no money. Keep your rights.
September 28, 2024
Yourself
This is the only option that allows you to keep your right to sue
about the claims in this lawsuit. You will not get any money
from the Settlement.

Your request to exclude yourself must be postmarked no later

than September 28, 2024.

Object Tell the Court why you do not like the Settlement. You will
September 28, 2024
still be bound by the Settlement if the Court approves it.
Objections must be postmarked no later than September
28, 2024.

Do Nothing If you do nothing, you remain in the Settlement. You give

up your rights to sue and you will not get any money.

 These rights and options, and the deadlines to exercise them, are explained in this Notice.

 The Court in charge of this case must still decide whether to approve the Settlement and
the requested attorneys’ fees and costs. No Settlement benefits or payments will be provided
unless the Court approves the Settlement and it becomes final.HIS NOTICE

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 WHAT THIS NOTICE CONTAINS

BASIC INFORMATION.....................................................................................................PAGE 4
1. Why is this Notice being provided?
2. What is this lawsuit about?
3. Why is the lawsuit a class action?
4. Why is there a Settlement?
WHO IS INCLUDED IN THE SETTLEMENT? ....................................................................PAGE 5
5. How do I know if I am part of the Settlement?
6. Are there exceptions to being included in the Settlement?
7. What if I am still not sure whether I am part of the Settlement?
THE SETTLEMENT BENEFITS—WHAT YOU GET IF YOU QUALIFY..................................PAGE 5
8. What does the Settlement provide?
9. What am I giving up to receive Settlement benefits or stay in the Settlement Class?
10. What are the Released Claims?
HOW TO GET BENEFITS FROM THE SETTLEMENT........................................................PAGE 7
11. How do I make a claim for Settlement benefits?
12. What happens if my contact information changes after I submit a claim?
13. When will I receive my Settlement benefits?
THE LAWYERS REPRESENTING YOU .............................................................................PAGE 7
14. Do I have a lawyer in this case?
15. How will Proposed Class Counsel be paid?
OPTING OUT FROM THE SETTLEMENT ..........................................................................PAGE 8
16. How do I get out of the Settlement?
17. If I opt out, can I get anything from the Settlement?
18. If I do not opt out, can I sue the Defendant for the same thing later?
OBJECTING TO THE SETTLEMENT..................................................................................PAGE 8
19. How do I tell the Court that I do not like the Settlement?
20. What is the difference between objecting and opting out?
THE FINAL FAIRNESS HEARING ..................................................................................PAGE 10
21. When and where will the Court decide whether to approve the Settlement?
22. Do I have to attend the Final Fairness Hearing?
23. May I speak at the Final Fairness Hearing?
IF YOU DO NOTHING .................................................................................................... PAGE 10
24. What happens if I do nothing at all?
GETTING MORE INFORMATION................................................................................... PAGE 11
25. How do I get more information?

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 BASIC INFORMATION
1. Why is this Notice being provided?
A federal court authorized this Notice because you have the right to know about the proposed
Settlement of this class action lawsuit and about all of your rights and options before the Court
decides whether to grant final approval to the Settlement. This Notice explains the lawsuit, the
Settlement, your legal rights, what benefits are available, who is eligible for the benefits, and
how to get them.

The Honorable Gershwin A. Drain of the United States District Court for the Eastern District of
Michigan is overseeing this class action. The case is known as In Re Henry Ford Health System
Data Security Litigation, Case No. 23-cv-11736-GAD-KGA (E.D. Mich.) (the “Litigation”).
The people who filed this lawsuit are called the “Plaintiffs” or “Representative Plaintiffs” and
the company sued, Henry Ford Health System is called “Henry Ford” or the “Defendant.”

2. What is this lawsuit about?

The Plaintiffs allege that on or around March 30, 2023, an unauthorized user launched a targeted
cybersecurity attack on Henry Ford’s network and computer systems (the “Data Security
Incident”), which potentially resulted in unauthorized access to names, genders, dates of birth,
ages, lab results, procedure types, diagnoses, dates of service, telephone numbers, medical record
numbers and/or internal tracking numbers (the “Personal Information”) of Settlement Class
Members. Plaintiffs filed a lawsuit against Defendant, individually, and on behalf of anyone
whose Personal Information was potentially accessed, viewed, and/or obtained as a result of the
Data Security Incident.
The Defendant denies any wrongdoing, and no court or other entity has made any judgment or
other determination of any wrongdoing, or that any law has been violated. The Defendant denies
these and all other claims made in the Litigation. By entering into the Settlement, the Defendant
is not admitting any wrongdoing.

3. Why is the lawsuit a class action?

In a class action, Representative Plaintiffs sue on behalf of all people who have similar claims.
Together, all these people are called a Settlement Class or Settlement Class Members. One court
resolves the issues for all Settlement Class Members, except for those Settlement Class Members
who timely exclude themselves (opt out) from the Settlement Class.
The Representative Plaintiffs in this case are Briana Tabbs, Latricia Pelt, Brandi McKenzie and
David King.

4. Why is there a settlement?

Plaintiffs and the Defendant do not agree about the claims asserted in this Litigation. The
Litigation has not gone to trial, and the Court has not decided in favor of the Plaintiffs or the
Defendant. Instead, Plaintiffs and the Defendant have agreed to settle the Litigation. Plaintiffs
and the attorneys for the Settlement Class (subject to final approval, court-appointed “Proposed
Settlement Class Counsel” or “Proposed Class Counsel”) believe the Settlement is best for all
Settlement Class Members because of the Settlement benefits and the risks and uncertainty
associated with continued litigation and the nature of the defenses raised by the Defendant.

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 WHO IS INCLUDED IN THE SETTLEMENT?
5. How do I know if I am part of the settlement?
You are a Settlement Class Member if you reside in the United States and were mailed a
notice letter from Henry Ford notifying you that your Personal Information was potentially
accessed, viewed, and/or obtained in the Data Security Incident that occurred on or around
March 30, 2023.

6. Are there exceptions to being included in the settlement?

Yes. Excluded from the Settlement Class are (1) the Judges presiding over the Action and
members of their immediate families and their staff; (2) Henry Ford, its subsidiaries, parent
companies, successors, predecessors, and any entity in which Henry Ford or its parents, have a
controlling interest, and its current or former officers and directors; (3) natural persons who
properly execute and submit a Request for Exclusion prior to the expiration of the Opt-Out
Period; and (4) the successors or assigns of any such excluded natural person.

7. What if I am not sure whether I am part of the settlement?

If you are still not sure whether you are a Settlement Class Member, you may go to the
Settlement website at www.hfhsdatasecuritysettlement.com or call the Claims Administrator’s
toll-free number at 1-866-742-4955.

THE SETTLEMENT BENEFITS – WHAT YOU GET IF YOU QUALIFY

8. What does the settlement provide?
If you are a Settlement Class Member, you may be able to recover the following Claimed
Benefits as part of the Settlement:

CLAIMED BENEFITS:
All Settlement Class Members must submit a valid and timely Claim Form to receive any of
the following Claimed Benefits:

Credit Monitoring and Insurance Services (“CMIS”)

The CMIS benefit will provide one credit bureau monitoring services and $1 million in identity
theft insurance for two years. The CMIS benefits will be available to class members irrespective
of whether they took advantage of any previous offering of credit monitoring from Henry Ford.
Individuals who obtained CMIS services from another provider as a result of the Data Security
Incident will be permitted to postpone activation of their CMIS settlement benefit for up to 12
months.

-AND-

1. Documented Loss Payment

Settlement Class Members who submit a valid and timely Claim Form are eligible to receive
reimbursement of up to $2,500 per Settlement Class Member for their Documented Loss that is
more likely than not traceable to the Data Security Incident Payment (the total aggregate
payments for such claims may not exceed $25,000).

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These Documented Losses may include:
(1) Unreimbursed losses relating to fraud or identity theft;
(2) Professional fees including attorneys’ and accountants’ fees, and fees for credit repair
services;
(3) Costs associated with freezing or unfreezing credit with any credit reporting agency;
(4) Credit monitoring costs that were incurred that you attest were caused or otherwise
incurred as a result of the Data Security Incident; and
(5) Miscellaneous expenses such as notary, data charges (if charged based on the amount of
data used) fax, postage, copying, mileage, cell phone charges (only if charged by the
minute), and long-distance telephone charges.

You must submit documentation of the Documented Losses as part of your Documented Loss
Claim. This may include credit card statements, bank statements, invoices, telephone records,
and receipts. Documented Loss costs cannot be documented solely by a personal certification,
declaration, or affidavit from the Claimant. Class Members who submit a Claim for a Document
Loss payment will not be entitled to select a Cash Fund Payment.

-OR-

2. Cash Fund Payment

The amount of each Cash Fund Payment shall be calculated by dividing the remaining Net
Settlement Funds by the number of valid claims submitted for Cash Fund Payments, after the
CMIS benefit and the Document Loss payments have been made. Class Members who submit a
Claim for a Cash Fund Payment will not be entitled to select a Document Loss payment.

9. What am I giving up to receive Settlement benefits or stay in the Settlement

Class?
Unless you exclude yourself (opt out), you are choosing to remain in the Settlement Class. If the
Settlement is approved and becomes final, all Court orders will apply to you and legally bind
you. You will not be able to sue, continue to sue, or be part of any other lawsuit against the
Defendant and Released Persons about the legal issues in this Litigation that are released by this
Settlement. The specific rights you are giving up are called “Released Claims.”

10. What are the Released Claims?

The Settlement Agreement in Sections 4, 1.36 and 1.37 describes the Release, Released Claims,
and Released Parties in necessary legal terminology, so please read this section carefully. The
Settlement Agreement is available at www.hfhsdatasecuritysettlement.com or in the public
Court records on file in this lawsuit. For questions regarding the Releases or Released Claims
and what the language in the Settlement Agreement means, you can also contact one of the
lawyers listed in Questions 14 & 19 of this Notice for free, or you can talk to your own lawyer
at your own expense.

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 HOW TO GET BENEFITS FROM THE SETTLEMENT
11. How do I make a claim for Settlement Benefits?
To submit a claim for CMIS and reimbursement for a Documented Loss payment or Cash Fund
Payment, you must timely submit a valid Claim Form. Settlement Class Members seeking benefits
under the Settlement must complete and submit a Claim Form to the Claims Administrator,
postmarked or submitted online on or before October 28, 2024. Claim Forms may be submitted
online at www.hfhsdatasecuritysettlement.com or printed from the Settlement website and
mailed to the Claims Administrator at the address on the form. The quickest way to submit a
claim is online. Claim Forms are also available by calling 1-866-742-4955 or by writing to:
Henry Ford Health System Data Security Litigation
RG/2 Claims Administration, LLC
P.O. Box 59479
Philadelphia, PA 19102-9479

12. What happens if my contact information changes after I submit a claim?

If you change your mailing address after you submit a Claim Form, it is your responsibility to
inform the Claims Administrator of your updated information. You may notify the Claims
Administrator of any changes by calling 1-866-742-4955 or by writing to:

Henry Ford Health System Data Security Litigation

RG/2 Claims Administration, LLC
P.O. Box 59479
Philadelphia, PA 19102-9479

13. When will I receive my Settlement benefits?

If you file a timely and valid Claim Form, any CMIS benefit you select and your payment will
be provided by the Claims Administrator after the Settlement is approved by the Court and
becomes final.

It may take time for the Settlement to be approved and become final. Please be patient and check
www.hfhsdatasecuritysettlement.com for updates.

THE LAWYERS REPRESENTING YOU

14. Do I have a lawyer in this case?
Subject to final approval, the Court has provisionally appointed Interim Lead Counsel The
Miller Law Firm, P.C. as Settlement Class Counsel to represent you and the Settlement Class
for the purposes of this Settlement. You may hire your own lawyer at your own cost and expense
if you want someone other than Class Counsel to represent you in this litigation.

15. How will Proposed Class Counsel be paid?

Proposed Class Counsel will file a motion asking the Court to award attorneys’ fees and costs
not to exceed (1/3) of the Settlement Fund, or approximately $233,333.33. They will also ask
the Court to approve service awards for up to $1,500 to each of the Class Representatives for
participating in this Litigation and for their efforts in achieving the Settlement. If awarded by

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the Court, attorneys’ fees and costs and the service awards will be paid out of the Settlement
Fund. The Court may award less than these amounts.
Proposed Class Counsel’s application for attorneys’ fees, costs, and service awards will be made
available on the Settlement website at www.hfhsdatasecuritysettlement.com before the
deadline for you to comment or object to the Settlement.

OPTING OUT FROM THE SETTLEMENT

If you are a Settlement Class Member and want to keep any right you may have to sue or
continue to sue the Defendant on your own based on the claim raised in this Litigation or released
by the Released Claims, then you must take steps to get out of the Settlement. This is called
excluding yourself from or “opting out” of the Settlement.

16. How do I get out of the Settlement?

To opt out of the Settlement, you must mail a written notice of intent to opt out. The written
notice must be signed, include your name and address, and clearly state that you wish to be
excluded from the Settlement Class.
The opt-out request must be postmarked and set to the Claims Administrator at the following
address by September 28, 2024:

Henry Ford Health System Data Security Litigation

RG/2 Claims Administration, LLC
P.O. Box 59479
Philadelphia, PA 19102-9479

You cannot exclude yourself by telephone or by email.

17. If I opt out, can I get anything from the Settlement?

No. If you opt out, you give up any right to sue the Defendant and Released Parties for the claims
this Settlement resolves and Releases relating to the Data Security Incident. You must opt out
of this Litigation to start or continue with your own lawsuit or be part of any other lawsuit against
the Defendant or any of the Released Parties. If you have a pending lawsuit, speak to your lawyer
in that case immediately.

18. If I do not opt out, can I sue the Defendant for the same thing later?
No. Unless you opt out, you give up any right to sue the Defendant and Released Parties for the
claims this Settlement resolves and Releases relating to the Data Security Incident. You must
opt out of this Litigation to start or continue with your own lawsuit or be part of any other lawsuit
against the Defendant or any of the Released Parties. If you have a pending lawsuit, speak to
your lawyer in that case immediately.

OBJECTING TO THE SETTLEMENT

19. How do I tell the Court that I do not like the Settlement?
If you are a Settlement Class Member, you can tell the Court you do not agree with all or any
part of the Settlement or requested attorneys’ fees and costs. You can also give reasons why you
think the Court should not approve the Settlement or attorneys’ fees and costs. To object, you

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must file timely written notice as provided below no later than September 28, 2024, stating you
object to the Settlement. The objection must include all the following additional information:
(1) The case name and docket number, In Re Henry Ford Health System Data Security
Litigation, Case No. 23-cv-11736-GAD-KGA (E.D. Mich.);
(2) Your full name, current mailing address, and telephone number;
(3) A statement by you that you believe yourself to be a member of the Settlement Class;
(4) Proof that you are a member of the Settlement Class (e.g., copy of the settlement
notice, copy of the original notice of the Data Security Incident);
(5) The specific factual and legal grounds for the objection;
(6) Whether the Objection is an objection to the Settlement in part or in whole;
(7) Whether the objection applies only to you, a subset of the Settlement Class, or the
entire Settlement Class;
(8) All counsel representing you, if any;
(9) A list, including case name, court, and docket number, of all other cases in which
you and/or your counsel has filed an objection to any proposed class action settlement
in the past five (5) years;
(10) All documents or writings that you want the Court to consider;
(11) A statement regarding whether you or your counsel intends to appear at the Final
Approval Hearing; and
(12) Your signature or your duly authorized attorney or representative’s signature.

To be timely, written notice of an objection in the appropriate form containing the case name
and docket number (In Re Henry Ford Health System Data Security Litigation, Case No. 23-cv-
11736- GAD-KGA (E.D. Mich.)) must be filed with the Court by September 28, 2024, with
copies to Proposed Class Counsel and Counsel for Defendant:

Court Proposed Class Counsel Counsel for Defendant

Hon. Gershwin A. Drain E. Powell Miller Michelle R. Gomez
U.S. District Court, E.D. The Miller Law Firm, P.C Baker & Hostetler LLP
Mich., Theodore Levin U.S. 950 W University Dr., Ste. 300 1801 California St, Ste 4400
Courthouse Rochester, MI 48307 Denver, CO 80202-2662
231 W. Lafayette Blvd., (248) 609-7331 (303) 861-0600
Detroit, Michigan 48226

Any Settlement Class Member who fails to comply with the requirements for objecting in
Section 6 of the Settlement Agreement waives and forfeits any and all rights they may have to
appear separately and/or to object to the Settlement Agreement and will be bound by all the
terms of the Settlement Agreement and by all proceedings, orders and judgments in the
Litigation.
Any objector or his or her counsel may also file Objections with the Court through the Court’s
Electronic Claims Filing system, with service on Proposed Settlement Class Counsel and
Defendant’s Counsel made through the Electronic Claims Filing system. For all objections
mailed to Proposed Settlement Class Counsel and counsel for Defendant, Settlement Class
Counsel will file them with the Court with the Motion for Final Approval of the Settlement.

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 20. What is the difference between objecting and asking to opt out?
Objecting is simply telling the Court you do not like something about the Settlement or requested
attorneys’ fees and costs. You can object only if you stay in the Settlement Class (meaning you
do not opt out of the Settlement). Opting out of the Settlement is telling the Court you do not
want to be part of the Settlement Class or the Settlement. If you opt out, you cannot object to
the Settlement.

THE FINAL FAIRNESS HEARING

21. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Final Fairness Hearing on October 29, 2024, at 11:00 a.m., before Judge
Gershwin A. Drain, at the United States District Court for the Eastern District of Michigan,
Theodore Levin U.S. Courthouse, 231 W. Lafayette Blvd., Detroit, Michigan 48226.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate
and decide whether to approve the Settlement, Proposed Class Counsels’ application for
attorneys’ fees, costs and expenses, and the service awards to the Plaintiff. If there are objections,
the Court will consider them. The Court will also listen to people who have asked to speak at the
hearing.
Note: The date and time of the Final Fairness Hearing are subject to change. The Court may also
decide to hold the hearing via Zoom or by phone. Any change will be posted at
www.hfhsdatasecuritysettlement.com.

22. Do I have to attend the Final Fairness Hearing?

No. Proposed Class Counsel will answer any questions the Court may have. However, you are
welcome to attend at your own expense. If you send an objection, you do not have to come to
Court to discuss it. As long as you timely file or mail your written objection, the Court will
consider it.

23. May I speak at the Final Fairness Hearing?

Yes, as long as you do not exclude yourself (opt out), you can (but do not have to) participate
and speak for yourself in this Litigation and Settlement. This is called making an appearance.
You also can have your own lawyer speak for you, but you will have to pay for the lawyer
yourself. If you want to appear, or if you want your own lawyer instead of Proposed Class
Counsel to speak for you at the hearing, you must follow all of the procedures for objecting to
the Settlement listed in Question 19 above—and specifically include a statement whether you
and your counsel will appear at the Final Fairness Hearing.

IF YOU DO NOTHING
24. What happens if I do nothing at all?
If you are a Settlement Class Member and do nothing, you will not receive any Settlement
benefits. You will give up rights explained in the “Opting Out from the Settlement” section of
this Notice, including your right to start or continue with a lawsuit, or be part of any other lawsuit
against Defendant, the Related Entities, or any of the Released Persons about the legal issues in

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this Litigation that are released by the Settlement Agreement relating to the Data Security
Incident.
GETTING MORE INFORMATION
25. How do I get more information?
This notice summarizes the proposed Settlement. Complete details are provided in the
Settlement Agreement. The Settlement Agreement and other related documents are available at
www.hfhsdatasecuritysettlement.com, by calling 1-866-742-4955, or by writing to:

Henry Ford Health System Data Security Litigation

RG/2 Claims Administration, LLC
P.O. Box 59479
Philadelphia, PA 19102-9479
[email protected]

PLEASE DO NOT CALL THE COURT OR

THE COURT’S CLERK OFFICE, DEFENDANT, OR DEFENDANT’S COUNSEL
REGARDING THIS NOTICE.

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