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The Court authorized this Notice because you have a right to know about the Settlement, and all of your options, before the Court decides whether to give final approval to the Settlement. This Notice explains the nature of the Class Action Lawsuit that is the subject of the Settlement, the general terms of the Settlement, and your legal rights and options.
The Judge Craig J. Bobay of the Allen County Superior Court 2 Indiana Commercial Court is overseeing this case captioned as In re: Leaders Staffing Data Incident Litigation, Case No. 02D02-2410-PL-000502. The Persons who brought the lawsuit are called the Settlement Class Representatives. The company being sued, Leaders Staffing LLC, is called the Defendant.
The Class Action Lawsuit alleges that on or about January 11, 2024, criminal actors illegally accessed limited portions of Leaders Staffing’s computer network and potentially gained unauthorized access to the sensitive personal information, collectively Protected Information of certain individuals who used Leaders Staffing’s staffing services in search of employment or who obtained employment through its staffing services, or the Third-Party Illegal Hacking event. The Protected Information that could have been subject to the Third-Party Illegal Hacking event includes name, Social Security Number, driver’s license number, and financial account information.
Defendant denies any wrongdoing whatsoever. No court or other judicial body has made any judgment or other determination that Defendant has done anything wrong.
In a class action, one or more people called “Settlement Class Representatives” or “Representative Plaintiffs” sue on behalf of all people who have similar claims. Together, all of these people are called a “Settlement Class,” and the individuals are called “Settlement Class Members.” One court resolves the issues for all Settlement Class Members, except for those who exclude themselves from the Settlement Class.
The Court has not decided in favor of the Plaintiffs or Defendant. Instead, both sides agreed to the Settlement. The Settlement avoids the cost and risk of a trial and related appeals, while providing benefits to Settlement Class Members. The Settlement Class Representatives appointed to represent the Settlement Class, and the attorneys for the Settlement Class, Class Counsel, think the Settlement is best for all Settlement Class Members.
You are affected by the Settlement and potentially a Settlement Class Member if you are an individual who received actual or constructive notice and/or were mailed a notice by Leaders Staffing that their information may have been compromised as a result of the Third-Party Illegal Hacking event and/or as a result of prior unauthorized access to or disclosure of Protected Information.
Excluded from the Settlement Class are: (1) the judges presiding over the Class Action Lawsuit, members of their staff, and members of their direct families; (2) Defendant and any other Releasee; (3) Settlement Class Members who submit a valid Request for Exclusion prior to the Opt-Out Deadline.
If you are not sure whether you are included in the Settlement, you may call (833) 420-4470 with questions. You may also write with questions to:
In re: Leaders Staffing Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324
The Settlement provides the following Settlement Payments available to Settlement Class Members who submit Approved Claims: (a) reimbursement for Out-of-Pocket Losses or Expenses of up to $1,500; and/or (b) Pro Rata Cash Payment.
Settlement Class Members that submit a valid and timely Claim Form may select one or more of the following Settlement Payments:
- Reimbursement for Out-of-Pocket Losses or Expenses. Settlement Class Members may submit a claim for a reimbursement for Out-of-Pocket Losses or Expenses of up to $1,500 per Person who is a Settlement Class Member, upon submission of a claim and supporting documentation, for Out-of-Pocket Losses or Expenses that are fairly traceable to and reasonably resulting from the Third-Party Illegal Hacking event;
- These losses may include: unreimbursed losses relating to fraud or identity theft; professional fees including attorneys’ fees, accountants’ fees, and fees for credit repair services; costs associated with freezing or unfreezing credit with any credit reporting agency; credit monitoring costs that were incurred on or after the date of the Third-Party Illegal Hacking event through the date of claim submission; and miscellaneous expenses such as notary, fax, postage, copying, mileage, and long-distance telephone charges.
- To receive reimbursement for Out-of-Pocket Losses or Expenses, Settlement Class Members must submit an Approved Claim (either in paper form or on the Settlement Website) that includes the following:
- third-party documentation supporting the loss; and
- a brief description of the documentation describing the nature of the costs, if the nature of the costs is not apparent from the documentation alone.
- Documentation can include receipts or other documentation not “self-prepared” by the claimant that document the costs incurred. “Self-prepared” documents such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but can be considered to add clarity or support other submitted documentation.
AND/OR
- Pro Rata Cash Payment. After the distribution of the Fee Award and Costs, Notice and Administrative Expenses, Service Award Payments, and Out-of-Pocket Losses or Expenses, the Settlement Administrator will make pro rata cash Settlement Payments of the remaining Settlement Fund to each Settlement Class Member who submits an Approved Claim for this benefit. This Pro Rata Cash Payment may be selected by itself or in addition to a claim for Out-of-Pocket Losses or Expenses.
- In the event that the aggregate amount of all payments for reimbursement of Out-of-Pocket Losses or Expenses exceeds the total amount of the Net Settlement Fund, then the value of such payments shall be reduced on a pro rata basis, such that the aggregate value of all payments for Out-of-Pocket Losses or Expenses does not exceed the Net Settlement Fund.
To receive a Settlement Payment, you must complete and submit a Claim Form online at www.LeadersSettlement.com or by mail to In re: Leaders Staffing Data Incident Litigation, c/o Kroll Settlement Administration LLC, P.O. Box 5324, New York, NY 10150-5324. Read the Claim Form instructions carefully, fill out the Claim Form, provide the required documentation, and submit online by September 22, 2025, or by mail postmarked by September 22, 2025.
TO RECEIVE AN ELECTRONIC OR ACH PAYMENT FOR YOUR APPROVED CLAIM, YOU MUST FILE A CLAIM FORM ONLINE HERE
The Court will hold a Final Approval Hearing on September 8, 2025, at 3:00 p.m. ET to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals from that decision and resolving them can take time. It also takes time for all of the Claim Forms to be processed. Please be patient. Settlement Payments will begin after the Settlement has obtained Court approval and the time for all appeals has expired.
Defendant and its affiliates will receive a Release from all Claims that could have been or that were brought against Defendant relating to the Third-Party Illegal Hacking event. Thus, if the Settlement becomes final and you do not exclude yourself from the Settlement, you will be a Settlement Class Member and you will give up your right to sue Leaders Staffing and all past, present, and future Subsidiaries and/or Affiliates (including any and all in-house and outside counsel including, without limitation, Leaders Staffing’s Counsel) and its and/or their past, present, and future advisors, administrators, auditors (including any and all internal and external auditors), employees, accountants, members, owners, actuaries, consultants, fiduciaries, representatives, service providers, Successors, successors-in-interest, parents, trustees, insurance carriers, reinsurers, estates, heirs, executors, beneficiaries, trusts, and assigns of, including all persons controlling, controlled by, or under common control with, any or all of the above persons or entities referenced in this paragraph, and assigns of each of them as well as covered entities associated with the Third-Party Illegal Hacking event. The Released Claims are described in Section 14 of the Settlement Agreement, which is available at here. If you have any questions, you can talk to the law firms listed in Question 17 for free or you can talk to your own lawyer.
No. If you exclude yourself, you will not be entitled to receive any Settlement Payments from the Settlement.
No. Unless you exclude yourself, you give up any right to sue Leaders Staffing and any other Parties for any Claim that could have been or was brought relating to the Third-Party Illegal Hacking event. You must exclude yourself from the Settlement to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case.
To exclude yourself, send a Request for Exclusion or written notice of intent to opt-out that says you want to be excluded from the Settlement. The Request for Exclusion must include the name of the Class Action Lawsuit, the individual’s full name, current address, personal signature, and the words “Request for Exclusion” or a comparable statement that the individual does not wish to participate in the Settlement at the top of the communication. You must mail your Request for Exclusion to the Settlement Administrator postmarked byJuly 24, 2025, to:
In re: Leaders Staffing Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324
Any Settlement Class Member who does not file a timely Request for Exclusion in accordance with the above will lose the opportunity to exclude himself or herself from the Settlement and will be bound by the Settlement.
You can tell the Court that you do not agree with the Settlement, or some part of it by objecting to the Settlement. For an objection to be a valid objection under the Settlement, it must be mailed to the Settlement Administrator at the address listed below, postmarked by no later than July 24, 2025.
In re: Leaders Staffing Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324
The written objection must include:
- the name of the Class Action Lawsuit;
- the Settlement Class Member’s full name, current mailing address, and telephone number;
- a statement of the specific grounds for the objection, as well as any documents supporting the objection;
- a statement as to whether the objection applies only to the objector, to a specific subset of the class, or to the entire class;
- the identity of any attorneys representing the objector;
- a statement regarding whether the Settlement Class Member (or his/her attorney) intends to appear at the Final Approval Hearing; and
- the signature of the Settlement Class Member or the Settlement Class Member’s attorney.
Any Settlement Class Member who does not file a timely and adequate objection in accordance with the above waives the right to object or to be heard at the Final Approval Hearing and shall be forever barred from making any objection to the Settlement
Objecting is telling the Court that you do not like the Settlement or parts of it and why you do not think it should be approved. You can object only if you are a Settlement Class Member. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class and do not want to receive any benefit from the Settlement.
Yes. The Court appointed Lynn A. Toops and Amina A. Thomas of Cohen Malad, LLP. If you want to be represented by your own lawyer, you may hire one at your own expense.
Class Counsel will file a Fee Application for attorneys’ fees and reimbursement of Litigation Costs and Expenses to be paid from the Settlement Fund. Leaders Staffing agrees not to oppose Class Counsel’s request for attorneys’ fees not to exceed one-third (33.33%) of the Settlement Fund, or $183,315, and reimbursement of reasonable Litigation Costs and Expenses not to exceed $50,000. The amount of Fee Award and Costs to be awarded will be decided by the Court.
Class Counsel’s Fee Application will also include a request for Service Award Payments for the Settlement Class Representatives in recognition for their contributions to this Class Action Lawsuit. Leaders Staffing agrees not to oppose Class Counsel’s request for a Service Award Payment not to exceed $2,000 per Settlement Class Representative.
The Court will hold a Final Approval Hearing on September 8, 2025, at 3:00 p.m. ET, at the Allen County Courthouse, 715 South Calhoun Street, Fort Wayne, Indiana 46802, Room 316 or via video or teleconference as ordered by the Court. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely and valid 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 Class Counsel’s Fee Application for Fee Award and Costs, and Service Awards Payments. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take. The hearing may be moved to a different date or time without additional notice, so Class Counsel recommends checking this Settlement Website, or calling (833) 420-4470.
No. Class Counsel will present the Settlement Class 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 visit 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 15, 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 15, including all the information required. Your objection must be mailed to the Settlement Administrator, at the mailing address listed above, postmarked by no later than July 24, 2025.
If you do nothing, you will not receive any Settlement Payments from this Settlement. If the Settlement is granted final approval and becomes final, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Leaders Staffing or the Releasees based on any claim that could have been or that was brought relating to the Third-Party Illegal Hacking event.
This Notice summarizes the Settlement. More details are in the Settlement Agreement itself. A copy of the Settlement Agreement is available here. You may also call the Settlement Administrator with questions or to receive a Claim Form at (833) 420-4470.
It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below, calling toll-free (833) 420-4470 or at the Contact page here:
In re: Leaders Staffing Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324
This website is authorized by the Court, supervised by counsel to the Parties, and controlled by the Settlement Administrator approved by the Court. This is the only authorized website for this case.
For more information please call (833) 420-4470.
Claims Deadline
Monday, September 22, 2025You must submit your Claim Form online no later than Monday, September 22, 2025, or mail your completed paper Claim Form so that it is postmarked no later than Monday, September 22, 2025.Opt-Out Deadline
Thursday, July 24, 2025You must complete and mail your written Request for Exclusion so that it is postmarked no later than Thursday, July 24, 2025.Objection Deadline
Thursday, July 24, 2025You must file your objection(s) and/or notice of intent to appear at the Final Approval Hearing so that it is received no later than Thursday, July 24, 2025.Final Approval Hearing
Monday, September 08, 2025You can also ask to speak at the Final Approval Hearing on September 8, 2025, at 3:00 p.m. ET about the fairness of the Settlement, with or without your own attorney.
Important Dates
This website is authorized by the Court, supervised by counsel to the Parties, and controlled by the Settlement Administrator approved by the Court. This is the only authorized website for this case.
For more information please call (833) 420-4470.
Claims Deadline
Monday, September 22, 2025You must submit your Claim Form online no later than Monday, September 22, 2025, or mail your completed paper Claim Form so that it is postmarked no later than Monday, September 22, 2025.Opt-Out Deadline
Thursday, July 24, 2025You must complete and mail your written Request for Exclusion so that it is postmarked no later than Thursday, July 24, 2025.Objection Deadline
Thursday, July 24, 2025You must file your objection(s) and/or notice of intent to appear at the Final Approval Hearing so that it is received no later than Thursday, July 24, 2025.Final Approval Hearing
Monday, September 08, 2025You can also ask to speak at the Final Approval Hearing on September 8, 2025, at 3:00 p.m. ET about the fairness of the Settlement, with or without your own attorney.