Question 1

Why did I get the Notice?

Accepted Answer

The Court authorized the 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 of the
Settlement. The Notice explains the lawsuit, the Settlement, your legal rights,
what benefits are available, who is eligible for the benefits, and how to
receive those benefits.

The case is known as Kim Townsel v. Henderson & Walton Women’s Center, P.C.,
Case No. CV-2024-900914.00 in the Circuit Court of Jefferson County, Alabama
(the “Action”). The individual who filed the lawsuit, Kim Townsel, is called the
“Plaintiff” and “Class Representative” and the company that was sued, Henderson
& Walton Women’s Center, P.C., is called the “Defendant” or “Henderson.”

Question 2

What is this lawsuit about?

Accepted Answer

On February 29, 2024, as a result of a Cybersecurity Incident between February
11, 2022 - February 14, 2022, Plaintiff filed a Class Action Complaint
(“Complaint”) against Henderson, in the Circuit Court of Jefferson County,
Alabama, asserting causes of action for: (1) negligence; (2) negligence per se;
(3) breach of implied contract; (4) breach of fiduciary duty; and (5) unjust
enrichment, seeking to represent a nationwide class of aggrieved individuals.

Henderson does not in any way acknowledge, admit to, or concede any of the
allegations made in the Complaint, and expressly disclaims and denies any fault
or liability, or any charges of wrongdoing that have been or could have been
asserted in the Complaint.

To view the full Complaint, please go to the Important Documents
[/important-documents] page.

Question 3

Why is this a class action?

Accepted Answer

In a class action, one or more people called the “Plaintiff(s)”, or “Class
Representative(s)” sue on behalf of all people who have similar claims.
Together, all of these people are called a “Settlement Class” or “Settlement
Class Members.” One court resolves the issues for all Settlement Class Members,
except for those individuals who exclude themselves from the Settlement Class.

Question 4

Why is there a Settlement?

Accepted Answer

The Plaintiff and Defendant disagree over the legal claims made in this Action.
The Action has not gone to trial, and the Court has not decided in favor of the
Plaintiff or Defendant (collectively referred to as the “Parties”). Instead, the
Parties now agree to settle the Action entirely, without any admission of
liability or wrongdoing, with respect to all Released Claims of the Releasing
Parties.

Henderson has entered into the Agreement to resolve all controversies and
disputes arising out of or relating to the allegations made in the Complaint or
which could have been made in the Complaint, and to avoid litigation costs,
distractions, and disruption to its business operations associated with further
litigation.

Plaintiff has entered into the Agreement to recover on the claims asserted in
the Complaint, and to avoid the risk, delay, and uncertainty of continued
litigation.

Question 5

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

Accepted Answer

The Settlement Class includes all persons whose personal information and/or
protected health information was potentially compromised as a result of the
Cybersecurity Incident which occurred between February 11, 2022, and February
14, 2022.

Personal Information refers to the information collected by Henderson, directly
or indirectly, pertaining to its current and former patients, including, but not
limited to, dates of birth, Social Security numbers, medical information, health
insurance information, driver’s license numbers or state ID numbers.

FAQs

Get the Answers You Need

Basic Information

Who Is Included in the Settlement?

The Settlement Class Member Benefits

How to Get Settlement Benefits—Submitting a Claim Form

The Lawyers Representing You

Excluding Yourself from the Settlement

Object to or Comment on the Settlement

The Final Approval Hearing

If You Do Nothing

Getting More Information

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?

Who Is Included in the Settlement?

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

6. Are there exceptions to individuals who are included in the Settlement Class?

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

The Settlement Class Member Benefits

8. What does the Settlement provide?

9. Do I need to submit documentation with my Claim Form?

10. What am I giving up in order to receive a Settlement Benefit or stay in the Settlement Class?

11. What are the Released Claims?

How to Get Settlement Benefits—Submitting a Claim Form

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

13. Where do I send my completed Claim Form?

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

15. When and how will I receive the Settlement Benefits?

The Lawyers Representing You

16. Do I have a lawyer in this case?

17. How will Settlement Class Counsel be paid?

Excluding Yourself from the Settlement

18. How do I get out of the Settlement?

19. If I opt out of the Settlement, can I still receive Settlement Benefits?

20. If I do not opt out of the Settlement, can I sue the Defendant for the same thing later?

Object to or Comment on the Settlement

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

22. What is the difference between objecting and opting out?

The Final Approval Hearing

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

24. Do I have to come to the Final Approval Hearing?

25. May I speak at the Final Approval Hearing?

If You Do Nothing

26. What happens if I do nothing at all?

Getting More Information

27. How do I get more information?