Frequently Asked Questions

Basic Information

1. Why did I get the Notice?

2. What is this lawsuit about?

3. Why is this a class action?

4. Why is there a settlement?

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

8. What does the Settlement provide?

9. Can I get more information about the Medical Shield Complete Services?

10. Can I get more information about the Monetary Payments?

11. Can I get more information about the cash payments for Documented Time?

12. Can I get more information about the Cash Payments for Out-of-Pocket Losses?

13. Has Regents taken remedial measures in response to the data incident?

14. What is the total value of the Settlement?

15. What am I giving up to get a Settlement payment or stay in the Settlement Class?

16. What are the Released Claims?

How to Get Settlement Benefits – Submitting a Claim Form

17. How do I make a claim for Settlement Benefits?

18. How do I make a claim for Medical Shield Complete Services?

19. How do I make a claim for Monetary Payment?

20. How do I make a claim for a Cash Payment for Documented Time?

21. How do I make a claim for a Cash Payment for Out-of-Pocket Losses?

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

23. When and how will I receive the benefits I claim from the Settlement?

24. What happens if money remains after all of the Settlement Claims are paid?

The Lawyers Representing You

25. Do I have a lawyer in this case?

26. How will Class Counsel be paid?

Excluding Yourself from the Settlement

27. How do I exclude myself from the Settlement?

28. If I exclude myself, can I still get Medical Shield Complete and a Cash Payment?

29. If I do not exclude myself, can I sue the Defendant for the same thing later?

Object to or Comment on the Settlement

30. How do I tell the Court that I do not like the Settlement?

31. What is the difference between objecting and requesting exclusion?

The Final Fairness Hearing

32. When and where will the Court decide whether to approve the Settlement?

33. Do I have to come to the Final Fairness Hearing?

34. May I speak at the Final Fairness Hearing?

If You Do Nothing

35. What happens if I do nothing at all?

Getting More Information

36. How do I get more information?

Basic Information

1. Why did I get the Notice?

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

The Honorable Richard S. Whitney of the Superior Court of the State of California, County of San Diego, is overseeing this class action. The case is known as Tsvetanova, et al. v. The Regents of the University of California, Case No. 37-2021-00039888-CU-NP-CTL (San Diego Sup. Ct.) (the “Action”). The people who filed this lawsuit are called the “Plaintiffs,” and the company they sued, The Regents of the University of California, is called the “Defendant.”

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2. What is this lawsuit about?

In September 2021, Regents announced that, between December 2, 2020, and April 8, 2021, unauthorized parties accessed certain employee email accounts at the University of San Diego Health. These accounts contained personally identifiable information and protected health information of Plaintiffs and Settlement Class Members. Plaintiffs claim that the Defendant did not adequately protect its patients’ information. The Defendant denies any wrongdoing. No judgment or determination of wrongdoing has been made.

Plaintiffs claim that the Defendant failed to adequately protect their information and that they were injured as a result. The Defendant denies any wrongdoing. No court or other entity has made any judgment or other determination of any wrongdoing, or that the law has been violated. The Defendant denies the claims made by the Plaintiffs in the Action. By entering into the Settlement, the Defendant is not admitting any wrongdoing.

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3. Why is this a class action?

In a class action, one or more people called the Class Representatives sue on behalf of all people who have similar claims. Together all of these people are called a Class or Settlement Class Members. One court resolves the issues for all Settlement Class Members, except for those Settlement Class Members who exclude themselves from the Class. The three Class Representatives in this case are Desislava Tsvetanova, Sharon Palmer-Brownstein, and Hue Simone.

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4. Why is there a settlement?

The Class Representatives and the Defendant do not agree about the claims made in this Action. The Action has not gone to trial, and the Court has not decided in favor of the Class Representatives or the Defendant. Instead, the Class Representatives and the Defendant have agreed to settle the Action. The Class Representatives and the attorneys for the Class (“Class Counsel”) believe the Settlement is best for all Settlement Class Members because of the risks and uncertainty associated with continued litigation and the nature of the defenses raised by the Defendant.

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5. How do I know if I am part of the Settlement?

If you received a postcard notice of this Settlement, you have been identified as a Settlement Class Member. More specifically, you are a Settlement Class Member if your personal information or personal health information is known to have been impacted by the Data Security Incident, which occurred between December 2, 2020, and April 8, 2021.

If you believe you are a Settlement Class member, but you did not receive direct individual “Notice of Data Breach” on or around September 9, 2021, please email info@UCSDHealthBreachSettlement.com to verify whether you are a Settlement Class Member.

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

Yes, the Settlement does not include (i) any judge or magistrate judge presiding over this Action, members of their staff, and members of their immediate families; (ii) the Released Parties; (iii) persons who properly execute and file a timely request for exclusion from the Settlement Class; (iv) persons whose claims in this matter have been finally adjudicated on the merits or otherwise released; (v) counsel for the Regents; and (vi) the legal representatives, successors, and assigns of any such excluded persons.

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

If you are still not sure whether you are a Settlement Class Member, you may email the Settlement Administrator at info@UCSDHealthBreachSettlement.com.

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The Settlement Benefits – What You Get if You Qualify

8. What does the Settlement provide?

The Settlement will provide Settlement Class Members with the following benefits:

  • Two years of Medical Shield Complete, credit and medical monitoring and identity theft insurance services;

  • Monetary Payment depending on the number of Settlement Class Members who choose to participate in Settlement (the participation rate), the payment amount will be a pro rata share of the remaining Net Settlement Fund after all other Settlement Benefits have been paid, estimated to be between $169.69 and $33.94 if the claims rate is between 2% and 10%, before deducting payments for Documented Time and Out-of-Pocket Losses;

  • Cash payment of up to $175 for Documented Time, for up to seven hours of documented time fairly traceable to the Data Security Incident, valued at up to $25 per hour; and

  • Cash payment of up to $10,000 for Fraud/Out-of-Pocket Costs, for documented out-of-pocket losses fairly traceable to the Data Security Incident.

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9. Can I get more information about the Medical Shield Complete Services?

Medical Shield Complete provides a way to protect yourself from unauthorized use of your information. If you already have credit monitoring services, you may still sign up for this additional protection. Medical Shield Complete is being provided by CyEx by Pango Group. These Medical Shield Complete services include:

  • 1-Bureau Credit Monitoring
  • Health Insurance Plan Number Monitoring
  • Medical Record Number Monitoring
  • Medical Beneficiary Identifier Monitoring
  • National Provider Number Monitoring
  • International Classification of Diseases Monitoring
  • Dark Web Monitoring
  • High Risk Transaction Monitoring
  • Health Savings Account Monitoring
  • Real Time Authentication Alerts
  • Security Freeze Assist
  • Insight & Tips News Feeds on the Customer Dashboard
  • $1,000,000 Comprehensive Medical Identity Theft Insurance
  • Victim Assistance
  • Customer Support

More information about the Medical Shield Complete services being provided by CyEx through this Settlement is available at https://cyex.com/medical-shield.

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10. Can I get more information about the Monetary Payments?

You may qualify for a cash “Monetary Payment.”

Each participating Settlement Class Member who elects to receive a Monetary Payment will receive a check from the Settlement Fund. The amount will depend on the participation rate but will be each participating Settlement Class Member’s pro rata share of the Net Settlement Fund, after all other Settlement Benefits have been paid.

The following chart shows approximate Monetary Payment amounts before deducting payments for Out-of-Pocket Losses and Documented Time:

Participation Rate

Approx. Monetary Payment

1%

$339.37

2%

$169.69

3%

$113.12

4%

$84.84

5%

$67.87

6%

$56.56

8%

$42.42

10%

$33.94

If Monetary Payments are less than $5, the funds for Monetary Payment will instead be used to extend the Medical Shield Complete provided to all participating Settlement Class Members.

When you submit a valid Claim Form to the Settlement Administrator (via U.S. Mail or through the Online Claim Form) you will become a Participating Settlement Class Member. This means that you are electing to receive Credit Monitoring and a Monetary Payment under the Settlement.

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11. Can I get more information about the cash payments for Documented Time?

If you spent time remedying fraud, identity theft, or other misuse of your personal information that is fairly traceable to the Data Security Incident or time spent taking preventative measures to avoid such losses, you may qualify for an additional cash payment of up to $25 per hour for up to seven hours of time (up to $175).

To receive a Documented Time payment, you must state in the claim form the actual time spent remedying issues resulting from the Data Security Incident. You must also swear that the information you are providing is “true and accurate under penalty of perjury,” and provide Reasonable Documentation that demonstrates the time spent.

“Reasonable Documentation” means documentation supporting a claim, such as credit card statements, bank statements, invoices, telephone records, and receipts. Your personal certifications, declarations, or affidavits do not count as Reasonable Documentation, but may be included to provide clarification, context, or support for your claim.

Payments may be reduced pro rata depending on the number of Settlement Class Members that participate in the Settlement.

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12. Can I get more information about the Cash Payments for Out-of-Pocket Losses?

If you have unreimbursed costs or expenditures supported by Reasonable Documentation that you actually incurred and that are fairly traceable to the Data Security Incident, or if you spent money to protect yourself from future harm because of the Data Security Incident, you may make a claim for reimbursement of up to $10,000 in Out-of-Pocket Losses. Out-of-Pocket Losses consist of unreimbursed costs or losses and may include, without limitation, the following:

  1. Unreimbursed costs, expenses, losses, or charges incurred as a traceable result of identity theft or identity fraud, falsified tax returns, or other alleged misuse of a Settlement Class Member’s personal information;

  2. Costs incurred on or after December 2, 2020, associated with placing or removing a credit freeze on a Settlement Class Member’s credit file with any credit reporting agency;

  3. Other miscellaneous expenses incurred on or after December 2, 2020, related to any Out-of-Pocket Loss such as notary, fax, postage, copying, mileage, and long-distance telephone charges;

  4. Costs of credit reports, credit monitoring, or other products related to detection or remediation of identity theft incurred on or after December 2, 2020, through the date of the Settlement Class Member’s claim submission; and

  5. Any other Out-of-Pocket Loss fairly traceable to the Data Security Incident.

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13. Has Regents taken remedial measures in response to the data incident?

Regents has agreed to implement the following reasonable steps to secure its systems and environments from future threats:

  1. Updates to UCSDH’s password policy to strengthen password complexity requirements and implementation of updates;

  2. Revisions to existing policies and creation of new policies regarding encryption of email attachments and data loss prevention;

  3. Delivery of security and privacy communications and training on email practices;

  4. Implementation of solutions for the identification and reduction of ePHI within email and file systems;

  5. Implementation of network access controls for devices connected to UCSDH network;

  6. Implementation of a Privileged Access Management solution; and

  7. Ongoing monitoring of the above improvements.

The costs of any such improvements on the part of Regents are fully borne by Regents, and under no circumstances will such costs be deducted from the Settlement Fund.

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14. What is the total value of the Settlement?

Regents has agreed to pay US $2,950,000.00 to resolve all claims brought in this Action.

The $2,950,000.00 Settlement Fund will be used to provide:

  • The two years of Medical Shield Complete to each Settlement Class Member who submits a valid claim;

  • A cash payment for Monetary Payment if applicable;

  • An additional cash payment of up to $175 to each Settlement Class Member who submits a valid claim for Documented Time; and

  • A cash payment of up to $10,000 to each Settlement Class Member who submits a valid claim for Fraud/Out-of-Pocket Costs.

Any court-approved attorneys’ fees and costs; service awards to the Class Representatives; taxes due on any interest earned by the Settlement Fund, if necessary; and any notice and settlement administration expenses will be paid out of the Settlement Fund; and the balance (“Net Settlement Fund”) will be used to pay for the above benefits.

Additional information about how the Settlement value is calculated is available in the Settlement Agreement, which can be viewed here.

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15. What am I giving up to get a Settlement payment or stay in the Settlement Class?

Unless you exclude yourself, you are choosing to remain in the Settlement Class. If the Settlement is approved and becomes final, all of the Court’s orders will apply to you and legally bind you. You won’t be able to sue, continue to sue, or be part of any other lawsuit against the same parties about the legal issues in this Action that are resolved by this Settlement. The specific rights you are giving up are called Released Claims (see next question), and more information is provided in the Settlement Agreement which can be viewed here.

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16. What are the Released Claims?

In exchange for the Settlement, Settlement Class Members agree to release Regents and its past, present, and future direct and indirect heirs, assigns, associates, corporations, investors, owners, parents, subsidiaries, affiliates, divisions, officers, directors, shareholders, members, agents, employees, attorneys, insurers, reinsurers, benefit plans, predecessors, successors, managers, administrators, executors, and trustees, as well as Class Representatives and Class Counsel. These are called the “Released Parties.”

The release is from all claims, whether actual, potential, filed, unfiled, known, fixed or contingent, claimed or unclaimed, suspected or unsuspected claims, demands, liabilities, rights, causes of action, damages, punitive, exemplary or multiplied damages, expenses, costs, attorneys’ fees and/or obligations, whether in law or in equity, accrued or unaccrued, direct or indirect, individual or representative, of every nature and description whatsoever, based on any federal, state, local, statutory or common law or any other law, against the Released Parties, or any of them.

The release applies to claims arising out of or relating to actual or alleged facts, transactions, events, matters, occurrences, acts, disclosures, statements, representations, omissions or failures to act that are reasonably related to the same set of operative facts as alleged in the Complaint, including all claims relating to the Data Security Incident that were brought or could have been brought in the Action belonging to any and all Releasing Parties and claims for or under, without limitation, California’s Confidentiality of Medical Information Act (“CMIA”), California Consumer Privacy Act, California’s Unfair Competition Law, California’s Consumer Legal Remedies Act, California’s Information Practices Act, California Security Notification Laws (Cal. Civ. Code § 1798.82), negligence, breach of contract, breach of implied contract, quasi-contract for restitution, breach of confidence, and breach of fiduciary duty (“Released Claims”).

The Released Claims do not include claims against the cyber attacker(s) who committed the criminal acts involved in the Data Security Incident and persons or entities that intentionally misuse the information potentially compromised in the Data Security Incident for unlawful purposes.

More information is provided in the Settlement Agreement which is available here.

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How to Get Settlement Benefits – Submitting a Claim Form

17. How do I make a claim for Settlement Benefits?

Claim Forms may be submitted online here or mailed to the Settlement Administrator at the address on the form. Claim Forms are also available for download here or you may request one by emailing or writing to:

Tsvetanova, et al. v. The Regents of the University of California
c/o Settlement Administrator
P.O. Box 25921
Santa Ana, CA 92799
info@UCSDHealthBreachSettlement.com

The quickest way to file a claim is through the online claim form.

If you received a postcard notice by mail, please use your Online Claim Form login credentials, located at the bottom of the notice, to file your Claim Form here. If you lost or do not know your Online Claim Form login credentials, please email info@UCSDHealthBreachSettlement.com to obtain it. The deadline to complete and submit a Claim Form is July 31, 2025.

If you did not receive a postcard notice by mail, but believe you may be a Settlement Class member, you may still submit a paper claim here and provide your name and the last four digits of your social security number so the Settlement Administrator can verify whether you are a Settlement Class member.

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18. How do I make a claim for Medical Shield Complete Services?

If you received a postcard notice in the mail, you may use the Claim Form provided to file a claim for Medical Shield Complete. Simply provide your email address (required to obtain the medical and credit monitoring and insurance services), tear the Claim Form at the perforation, and place it in the mail postmarked on or before July 31, 2025. If you prefer not to provide your email address on the tear-away Claim Form mailed to you, you may instead submit a Claim Form here or mail a Claim Form to the Settlement Administrator. Directions for how to enroll in Medical Shield Complete will be emailed to the email address provided once the Settlement becomes final.

Instructions for filling out a claim for Credit Monitoring and Insurance Services are included on the Claim Form. The deadline to file a claim for Credit Monitoring and Insurance Services is July 31, 2025. You may file a claim for Medical Shield Complete in addition to claims for Monetary Payment, Documented Time, and Out-of-Pocket Losses.

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19. How do I make a claim for Monetary Payment?

If you received a postcard notice in the mail, you may use the Claim Form provided to file a claim for a cash payment. To file a claim for a Monetary Payment, simply tear the Claim Form at the perforation and place it in the mail postmarked on or before July 31, 2025. If you wish to receive your payment via electronic payment instead of a check, simply provide your email address (optional) on the Claim Form. If you would like to receive your payment via electronic payment, but would prefer not to provide your email address on the tear-away Claim Form mailed to you, you may instead submit a Claim Form here or mail a Claim Form to the Settlement Administrator.

Instructions for filling out a claim for Monetary Payment are included on the Claim Form. The deadline to file a claim for Monetary Payment is July 31, 2025. You may file a claim for Monetary Payment in addition to claims for Medical Shield Complete, Documented Time, and Out-of-Pocket Losses.

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20. How do I make a claim for a Cash Payment for Documented Time?

To file a claim for cash payment of up to $175 for Documented Time spent responding to the Data Security Incident, you must submit a valid Claim Form supported by Reasonable Documentation.

“Reasonable Documentation” is defined in Question 11.

These claims must be “fairly traceable” to the Data Security Incident. The Settlement Administrator will evaluate whether claims are fairly traceable based on guidelines provided in the Settlement Benefits Plan. Complete information is available here.

Instructions for filling out a claim for Documented Time are included on the Claim Form. The deadline to file a claim for Documented Time is July 31, 2025. You may file a claim for Documented Time in addition to claims for Medical Shield Complete, Monetary Payment, and Out-of-Pocket Losses. If your claim for Documented Time is rejected by the Settlement Administrator and you do not correct it, you may still receive compensation for a Monetary Payment.

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21. How do I make a claim for a Cash Payment for Out-of-Pocket Losses?

To file a claim for a cash payment of up to $10,000 for reimbursement of Out-of-Pocket Losses, you must submit a valid Claim Form electing to receive a payment for Out-of-Pocket Losses and Reasonable Documentation.

“Reasonable Documentation” is defined in Question 11.

These claims must be “fairly traceable” to the Data Security Incident. The Settlement Administrator will evaluate whether claims are fairly traceable based on guidelines provided in the Settlement Benefits Plan. Complete information is available here.

Instructions for filling out a claim for Out-of-Pocket Losses are included on the Claim Form. The deadline to file a claim for Fraud/Out-of-Pocket Costs is July 31, 2025. You may file a claim for Fraud/Out-of-Pocket Costs in addition to claims for Medical Shield Complete, Monetary Payment, and Documented Time.

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

If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by emailing or by writing to

Tsvetanova, et al. v. The Regents of the University of California
c/o Settlement Administrator
P.O. Box 25291
Santa Ana, CA 92799
info@UCSDHealthBreachSettlement.com

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23. When and how will I receive the benefits I claim from the Settlement?

If you make a valid claim for Medical Shield Complete, the Settlement Administrator will send you information on how to activate your medical and credit monitoring after the Settlement becomes final.

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24. What happens if money remains after all of the Settlement Claims are paid?

None of the money in the $2,950,000 Settlement Fund will be paid back to Defendant. If there is any money left in the Net Settlement Fund after the distribution of payments to Settlement Class Members, a subsequent Settlement Payment will be evenly made to all participating Settlement Class Members with Approved Claims, provided that the average check amount is equal to or greater than five dollars ($5.00). If the average check amount in a distribution would be less than five dollars ($5.00), the remaining Net Settlement Fund will be used to extend the Medical Shield Complete to participating Settlement Class Members receiving that benefit for as long as possible. Any residual funds remaining in the Net Settlement Fund will not revert to Regents and will be distributed to the Non-Profit Residual Recipient Privacy Rights Clearinghouse, a 26 U.S.C. § 501(c)(3) non-profit organization.

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The Lawyers Representing You

25. Do I have a lawyer in this case?

Yes, the Court has appointed as Class Counsel, Co-Lead Counsel Scott Edward Cole of Cole & Van Note, Norman E. Siegel of Stueve Siegel Hanson LLP, and Daniel S. Robinson of Robinson Calcagnie, Inc., 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 Action.

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26. How will Class Counsel be paid?

Class Counsel will file a motion asking the Court to award them attorneys’ fees and costs incurred in this case of up to $1,200,000.00. They will also ask the Court to approve service awards of $7,500.00 each to the three Class Representatives for participating in this Action and for their efforts in achieving the Settlement. If awarded, these amounts will be deducted from the Settlement Fund before making payments to Settlement Class Members. The Court may award less than these amounts.

Class Counsel’s application for attorneys’ fees, expenses, and service awards will be made available here before the deadline for you to comment or object to the Settlement. You can also request a copy of the application by contacting the Settlement Administrator by emailing info@UCSDHealthBreachSettlement.com.

Excluding Yourself 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 claims raised in this Action or released by the Released Claims, then you must take steps to exclude yourself or “opt-out” of the Settlement.

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27. How do I exclude myself from the Settlement?

To exclude yourself from the Settlement, you must mail a letter to the Settlement Administrator on or before July 1, 2025, requesting exclusion from the Settlement Class. The letter, called an Opt-Out request, must: (i) be in writing; (ii) provide the Settlement Class Member’s current address; (iii) contain the following statement: “I request that I be excluded from the Settlement Class in the case of Tsvetanova, et al. v. The Regents of the University of California”; (iv) be signed; and (v) be mailed to the Settlement Administrator at the following address:

Tsvetanova, et al. v. The Regents of the University of California
c/o Settlement Administrator
P.O. Box 25291
Santa Ana, CA 92799

To be valid, the written Opt-Out request must be postmarked or received by the Settlement Administrator on or before July 1, 2025.

Each individual who properly files a timely written Opt-Out request shall be excluded from the Settlement Class and shall have no rights under the Settlement Agreement. No Person may request to be excluded from the Settlement Class through “mass” or “class” opt-outs. Settlement Class members who fail to submit a valid and timely Opt-Out request on or before July 1, 2025 shall be bound by all terms of the Settlement and any final judgment entered in this Action if the settlement is approved by the Court

You cannot exclude yourself online, by telephone, or by email.

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28. If I exclude myself, can I still get Medical Shield Complete and a Cash Payment?

No. If you exclude yourself, you are telling the Court that you don’t want to be part of the Settlement. The only way to obtain settlement benefits including Medical Shield Complete and a cash payment, is to remain a Settlement Class Member and submit a valid Claim Form.

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29. If I do not exclude myself, can I sue the Defendant for the same thing later?

No. Unless you exclude yourself, you give up any right to sue the Defendant and Released Parties for the claims that this Settlement resolves. You must exclude yourself from this Action to start or continue 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, consult with your attorney in that case immediately.

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Object to or Comment on the Settlement

30. How do I tell the Court that I do not like the Settlement?

If you do not exclude yourself from the Settlement Class, you can object to the Settlement if you do not agree with any part of it. You can give reasons why you think the Court should deny approval by submitting an objection. To object, you can do so in writing, in person, or through counsel, at your own expense, at the Final Fairness Hearing.

If you object in writing, you must mail the objection by July 1, 2025, with the caption Tsvetanova, et al. v. The Regents of the University of California, et al., Case No. 37-2021-00039888-CU-NP-CTL, and include: (i) the Settlement Class Member’s full name, current mailing address, telephone number, and email address; (ii) a concise statement of the reasons for the objection, along with any supporting documentation that the person wishes the Court to consider; and (iii) the Settlement Class Member’s signature.

The objection must be postmarked no later than July 1, 2025, and mailed first-class postage prepaid to the Settlement Administrator and Counsel at the following addresses:

Settlement Administrator

Class Counsel

Defendant’s Counsel

Tsvetanova, et al. v. The Regents of the University of
California
c/o Settlement Administrator
P.O. Box 25291
Santa Ana, CA 92799















Norman E. Siegel
c/o Regents Data Breach Settlement
Stueve Siegel Hanson LLP
460 Nichols Road
Suite 200
Kansas City, MO 64112

Daniel S. Robinson
c/o Regents Data Breach Settlement
Robinson Calcagnie, Inc.
P.O. Box 2350
Newport Beach, CA 92658-8962

Scott Edward Cole
c/o Regents Data Breach Settlement
Cole & Van Note
555 12th Street
Suite 2100
Oakland, CA 94607

Jacob M. Heath
Orrick, Herrington & Sutcliffe LLP
1000 Marsh Road
Menlo Park, CA 94025-1015

Aravind Swaminathan
Orrick, Herrington & Sutcliffe Llp
401 Union Street
Suite 3300
Seattle, WA 98101









If such Objection is submitted and overruled by the Court, the objecting member of the Settlement Class will remain fully bound by the terms of the Settlement Agreement and the Final Approval Order.

The Parties will submit any responses to Objections no later than seven (7) days prior to the Final Fairness Hearing. The Court will hear from any Class Member who attends the Fairness Hearing and asks to speak regarding their objection, regardless of whether they have complied with the above procedures.

Any Settlement Class member who does not appear individually or through counsel and who does not challenge or comment upon the fairness and adequacy of the Settlement Agreement or Class Counsel’s request for Class Counsel Fees, Costs, and Expenses, or Service Awards shall waive and forfeit any and all rights to appear separately or object. All Settlement Class Members shall be bound by the Settlement and by all orders and judgments in this Action.

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31. What is the difference between objecting and requesting exclusion?

Objecting is informing the Court you do not like something about the Settlement. You can object only if you stay in the Settlement Class (that is, do not exclude yourself). Requesting exclusion is informing the Court you do not want to be part of the Settlement Class or participate in the Settlement. If you exclude yourself, you cannot object to the Settlement.

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The Final Fairness Hearing

32. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Fairness Hearing on October 3, 2025, at 10:30 a.m. before the Honorable Richard S. Whitney of the Superior Court of the State of California, County of San Diego, Hall of Justice, Fifth Floor, 330 W Broadway San Diego, CA 92101.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, and decide whether to grant final approval of the Settlement, approve Class Counsel’s application for attorneys’ fees and expenses as well as service awards to the Class Representatives. If there are objections, the Court will consider them. The Court will also hear from people who have asked to speak at the hearing.

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33. Do I have to come to the Final Fairness Hearing?

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you file and mail an objection, you do not have to attend the hearing. As long as you file and mail your written objection on time and as set forth above, it will be considered by the Court.

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34. May I speak at the Final Fairness Hearing?

Yes. The Court will hear from any Class Member who attends the Final Fairness Hearing and asks to speak regarding his or her objection.

If you filed an objection (see Question 29), your objection should state whether it is your intention to appear at the Final Fairness Hearing and should identify any witnesses you may call to testify or exhibits you intend to introduce into evidence at the Final Fairness Hearing. If you plan to have your attorney speak for you at the Final Fairness Hearing, your objection should also include your attorney’s name, address, and phone number.

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If You Do Nothing

35. What happens if I do nothing at all?

If you are a Settlement Class Member and you do nothing, you will remain a member of the Settlement Class but will not receive any Settlement benefits. You will also give up rights explained in Questions 15 and Question 16, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the Defendant or any of the Released Parties about the legal issues in this Action and released by the Settlement Agreement.

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Getting More Information

36. How do I get more information?

This website and the Notice summarize the proposed Settlement. Complete details are provided in the Settlement Agreement itself. The Settlement Agreement and other related documents are available here or you may write to:

Tsvetanova, et al. v. The Regents of the University of California
c/o Settlement Administrator
P.O. Box 25291
Santa Ana, CA 92799

Publicly filed documents can also be obtained by visiting the office of the Clerk of the San Diego County Superior Court or reviewing the Court’s online docket.

If you have questions, you may contact Class Counsel at:

Norman E. Siegel
c/o Regents Data Breach Settlement
Stueve Siegel Hanson LLP
460 Nichols Road
Suite 200
Kansas City, MO 64112

Daniel S. Robinson
c/o Regents Data Breach Settlement
Robinson Calcagnie, Inc.
P.O. Box 2350
Newport Beach, CA 92658-8962

Scott Edward Cole
c/o Regents Data Breach Settlement
Cole & Van Note
555 12th Street
Suite 2100
Oakland, CA 94607

PLEASE DO NOT CONTACT THE COURT REGARDING THE NOTICE. THE COURT CANNOT ANSWER ANY QUESTIONS.

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