Frequently Asked Questions

The Court authorized this notice because you have a right to know about the proposed Settlement in this class action lawsuit and about all of your options before the Court decides whether to give “final approval” to the Settlement. This notice explains the legal rights and options that you may exercise before the Court decides whether to approve the Settlement.

Judge Glenda Sanders of Superior Court of the State of California, for the County of Orange is overseeing this case. The case is known as Magallanes, et al. v. Discovery Practice Management, Inc., Case No. 0-2021-01213556-CU-MC-CXC. The persons who sued are called the Plaintiffs. DPM is called the Defendant.

The lawsuit alleges that DPM was responsible for the Data Incident and asserts claims such as: violations of the California Confidentiality of Medical Information Act, California’s Unfair Competition Law, and California Customer Records Act. The lawsuit seeks compensation for people who experienced unreimbursed, documented out-of-pocket expenses, fraudulent charges, and/or lost time spent dealing with the aftermath / clean-up of the Data Incident; or unreimbursed, documented extraordinary monetary losses as a result of the Data Incident.

DPM denies all of the Plaintiffs’ claims and maintains that it did not do anything wrong.

In a class action, one or more people called “Representative Plaintiffs” sue on behalf of all people who have similar claims. All of these people together are the “Class” or “Class Members.” In this case, the Representative Plaintiffs are JeanPaul Magallanes and Jennifer Galluzzo. One Court resolves the issues for all Class Members, except for those who exclude themselves from the Class.

By agreeing to settle, both sides avoid the cost and risk of a trial, and people who submit valid claims will get compensation. The Representative Plaintiffs and their attorneys believe the Settlement is fair, reasonable, and adequate and, thus, best for the Class and its members. The Settlement does NOT mean that DPM did anything wrong.

You are included in the Settlement Class if you were notified by mail of the Data Incident in 2021, and you were a person residing in the United States whose personally identifiable information (PII) was potentially compromised in the Data Incident.

Specifically excluded from the Settlement Class and California Settlement Subclass are: (i) natural persons who are directors or officers, of DPM; (ii) DPM’s parents, subsidiaries, affiliates, and any entity in which DPM has a controlling interest; (iii) all individuals who make a timely election to be excluded from this proceeding using the correct protocol for opting out; (iv) any and all federal, state, or local governments, including but not limited to their departments, agencies, divisions, bureaus, boards, sections, groups, counsels and/or subdivisions; (v) the attorneys representing the Parties in the Litigation; (vi) all judges assigned to hear any aspect of the Litigation, as well as their immediate family members; and (vii) any person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the Data Incident, or who pleads nolo contendere to any such charge.

If you are not sure whether you are included in the Settlement, you may call 1-844-481-0301 with questions or visit www.DPMDataSettlement.com. You may also write with questions to DPM Claims Administrator, PO Box 1108, Baton Rouge, LA 70821. Please do not contact the Court with questions.

The Settlement will provide all Class Members with access to CyEx’s Identity Defense Total Service, free of charge, for a period of three (3) years from activation of the service, without the need to submit a Claim Form. A redemption code was included in the Short-Form Notice you received, which may be used to enroll in the Identity Defense Total Service. Enrollment must be completed no later than December 9, 2025. CyEx will activate the Identity Defense Total Service no later than March 7, 2026.

Additionally, the Settlement will provide payments to people who submit valid claims.
There are two types of general payments that are available:
(1) Ordinary Expense Reimbursement (Question 8) and
(2) Extraordinary Expense Reimbursement (Question 9).

You may submit a claim for either or both types of payments. You must also provide proof of your class membership in the form of the unique identifier provided in the notice you received by postcard. If you provide a bill or payment card statement as part of required proof for any part of your claim, you may redact unrelated transactions and all but the first four and last four digits of any account number. In order to claim each type of payment, you must provide related documentation with the Claim Form, and the expense for which you are submitting a claim form cannot have been reimbursed through any other source. As part of the Settlement, DPM has agreed to implement and/or maintain certain data security measures as set forth in Sections 1.11, 1.12, and 10.1 of the Settlement Agreement, , which is available here.

Class Members are each eligible to receive reimbursement of up to $250 (in total, per person) for the following categories of unreimbursed, documented out-pocket expenses resulting from the Data Incident:

• Cost to obtain credit reports;
• Fees relating to a credit freeze;
• Card replacement fees;
• Late fees;
• Overlimit fees;
• Interest on payday loans taken as a result of the Data Incident;
• Other bank or credit card fees;
• Postage, mileage, and other incidental expenses resulting from lack of access to an existing account;
• Costs associated with credit monitoring or identity theft insurance purchased prior to the, if purchased primarily as a result of the Data Incident; and
• up to four (4) hours of unreimbursed attested lost time (at $15 per hour) spent monitoring accounts, reversing fraudulent charges, or otherwise dealing with the aftermath / clean-up of the Data Incident (only if at least one full hour was spent and the Class Member provides a description of the activities performed during the time claimed as reflected in the Claim Form.

Class Members who had other extraordinary unreimbursed fraudulent charges or out-of-pocket losses and/or lost time incurred as a result of, or in resolving issues and losses caused by, the Data Incident, are eligible to make a claim for reimbursement of up to $1,000 per Class Member. As part of the claim, the Class Member must plausibly show that:

(1) it is an actual, documented, and unreimbursed monetary loss;
(2) the loss was caused by the Data Incident;
(3) the loss occurred during the time period from June 20, 2020 through and including the end of the Claims Deadline;
(4) the loss is not already covered by one or more of the categories in Question 8 or reimbursed through any other source; and
(5) a reasonable effort was made to avoid or seek reimbursement for the loss (including exhaustion of all available credit monitoring insurance and identity theft insurance).

More details are provided in the Settlement Agreement, which is available here.

To ask for a payment, you must complete and submit a Claim Form. Claim Forms are available here, or you may request one by mail by calling 1-844-481-0301. Read the instructions carefully, fill out the Claim Form, and mail it postmarked no later than November 24, 2025 to:

DPM Claims Administrator
P.O. Box 1108
Baton Rouge, LA 70821

The Claims Administrator will decide whether the information provided on a Claim Form is complete and valid. The Claims Administrator may require additional information from any claimant. If the required information is not provided timely, the claim will be considered invalid and will not be paid.

You do not have to do anything to remain in the Settlement, but if you want a payment you must submit a Claim Form postmarked by November 24, 2025.

If the Settlement becomes final, you will give up your right to sue for the claims being resolved by this Settlement. The specific claims you are giving up are described in Section 1.22 of the Settlement Agreement. You will be “releasing” DPM and all related people or entities as described in Section 6 of the Settlement Agreement. The Settlement Agreement is available here. The Settlement Agreement describes the released claims with specific descriptions, so read it carefully. If you have any questions you can talk to the law firm listed in Question 17 for free or, you can, of course, talk to your own lawyer at your own expense if you have questions about what this means.

No. If you exclude yourself, you will not be entitled to any benefits of the Settlement, but you will not be bound by any judgment in this case.

No. Unless you exclude yourself, you give up any right to sue for the claims that this Settlement resolves. You must exclude yourself from the Settlement Class to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. If you exclude yourself, do not submit a Claim Form to ask for a payment.

To exclude yourself, send a letter that says you want to be excluded from the Settlement in Magallanes, et al. v. Discovery Practice Management, Inc., Case No. 0-2021-01213556-CU-MCCXC. Include your name, address, and signature. You must mail your Exclusion Request postmarked by November 24, 2025, to:
DPM Settlement Exclusions
PO Box 1108
Baton Rouge, LA 70821

Yes. The Court appointed the following lawyer as “Class Counsel:” James M. Treglio, Esq. of Potter Handy LLP, 100 Pine St., Ste. 1250, San Francisco CA 94111, (415) 534-1911.

You will not be charged for this lawyer. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel will request the Court’s approval of an award for attorneys’ fees and reasonable costs and expenses of $130,000. Class Counsel will also request approval of an incentive award of $5,000 for each of the Representative Plaintiffs. Any amount that the Court awards for attorneys’ fees, costs, expenses, and an incentive award will be paid separately by DPM and will not reduce the amount of payments to Class Members who submit valid claims.

You can object to the Settlement if you do not like it or some part of it. The Court will consider your views. To do so, you must file a written objection in this case, Magallanes, et al. v. Discovery Practice Management, Inc., Case No. 30-2021-01213556-CU-MC-CXC, with the Clerk of the Court at the address below.

Your objection must include all of the following:

• your full name , address, telephone number, and e-mail address (if any);
• information identifying you as a Settlement Class Member, including proof that you are a member of the Settlement Class, which is described in response to Question 5;
• a written statement of all grounds for the objection, accompanied by any legal support for the objection that you believe is applicable;
• the identity of all counsel representing you, if any, in connection with your objection;
• a statement confirming whether you intend to personally appear and/or testify at the Final Approval Hearing;
• your signature or the signature of your duly authorized attorney or other duly authorized representative;

To be timely, written notice of an objection in the appropriate form must be mailed, with a postmark date no later than November 24, 2025, to Proposed Class Counsel and DPM’s counsel as set forth below.

For all objections mailed to Proposed Settlement Class Counsel and counsel for DPM, Proposed Settlement Class Counsel will file them with the Court with the Motion for Final Approval of the Settlement.

Objecting is telling the Court that you do not like the Settlement and why you do not think it should be approved. You can object only if you do not exclude yourself from the Class. Excluding yourself is telling the Court that you do not want to be part of the Class. If you exclude yourself, you have no basis to object because the case no longer affects you.

The Court will hold a Final Approval Hearing at 2:00 PM PST on February 5, 2026, at the Superior Court of the State of California, for the County of Orange, located at 751 West Santa Ana Boulevard, Courtroom CX 102, Santa Ana California 92701. The hearing may be moved to a different date or time without additional notice, so it is a good idea to check www.DPMDataSettlement.com or call 1-844-481-0301. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely objections, the Court will consider them and will listen to people who have asked to speak at the hearing if such a request has been properly made. The Court will also rule on the request for an award of attorneys’ fees and reasonable costs and expenses, as well as the request for an incentive award for each of the Representative Plaintiffs. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take.

No. Class Counsel will present the Settlement Agreement to the Court. You or your own lawyer are welcome to attend at your expense, but you are not required to do so. If you send an objection, you do not have to come to the Court to talk about it. As long as you filed your written objection on time with the Court and mailed it according to the instructions provided in Question 19, the Court will consider it.

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must file an objection according to the instructions in Question 19, including all the information required therein. Your Objection must be filed with the Clerk of the Court for the Superior Court of the State of California, for the County of Orange, by mailing it postmarked no later than November 24, 2025. In addition, you must mail a copy of your objection to both Class Counsel and Defense Counsel listed in Question 19, postmarked no later than November 24, 2025.

If you do nothing, you will get no benefits from this Settlement. Unless you exclude yourself, after the Settlement is granted final approval and the judgment becomes final, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against DPM about the legal issues in this case, ever again.

This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement here. You may also write with questions to DPM Claims Administrator, PO Box 1108, Baton Rouge, LA 70821. You can also get a Claim Form at the website here, or by calling the toll-free number, 1-844-481-0301.