McManus v. Gerald O. Dry, P.A., Case No. 22 CVS 001776

IN THE GENERAL COURT OF JUSTICE,
CABARRUS COUNTY, NORTH CAROLINA

If you were mailed a notice by Gerald O. Dry, P.A. (“Defendant”) regarding a cybersecurity incident that was discovered in February 2022, you may be eligible for monetary compensation and identity theft protection.

A state trial court authorized this Notice. This is not junk mail, an advertisement, or a solicitation from a lawyer.

To: All Persons to whom Gerald O. Dry, P.A. sent a notice of the Data Incident. (“Settlement Class”).

A settlement has been proposed in a class action lawsuit against Gerald O. Dry, P.A. (“Defendant”) relating to the potential compromise of personally identifiable information (“PII”) of current and/or former clients of Gerald O. Dry, P.A. due to a cyber-attack on Defendant’s computer network that was discovered in February 2022 (the “Data Incident”). The PII potentially compromised during the Data Incident includes names, Social Security numbers, driver’s license numbers, dates of birth, familial information, address, employment information, as well as direct deposit bank account information.

Settlement Class: If you received a notice of the Data Incident from Gerald O. Dry, P.A., you are likely a “Settlement Class Member.”

•The Settlement provides payments to people who submit valid claims for ordinary unreimbursed losses, such as out-of-pocket expenses, fees incurred for credit reports, credit monitoring, or other identity theft insurance product purchased between March 25, 2022 and the Claim Deadline, and lost time, and for other extraordinary unreimbursed monetary losses. The Settlement provides for a two (2) year-membership of IDX identity theft protection services for Settlement Class Members and provides for an automatic two (2)-year term extension for Settlement Class Members who previously signed up for the IDX identity theft protection offered by Defendant, and who claim the additional benefit here. In addition to these monetary and nonmonetary benefits, Gerald O. Dry, P.A. has implemented data-security enhancements to its computer systems to better protect your PII in the future. Your legal rights are affected regardless of whether you do or do not act. Read this Notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
SUBMIT A CLAIM FORM	This is the only way you can get payment.
EXCLUDE YOURSELF FROM THE SETTLEMENT	You will not get any payment from the Settlement, but you also will not release your claims against Gerald O. Dry, P.A. This is the only option that allows you to be part of any other lawsuit against Defendant or related parties for the legal claims resolved by this Settlement.
OBJECT TO THE SETTLEMENT	Write to the Court with reasons why you do not agree with the Settlement.
GO TO THE FINAL APPROVAL HEARING	You may ask the Court for permission for you or your attorney to speak about your objection at the Final Approval Hearing.
DO NOTHING	You will not get any payment from this Settlement, and you will give up certain legal rights. Submitting a Claim Form is the only way to obtain payment under this Settlement.

•These rights and options—and the deadlines to exercise them—are explained in the Notice. For complete details, view the Settlement Agreement. The Court in charge of this case still has to decide whether to grant final approval of the Settlement. Payments will only be made after the Court grants final approval of the Settlement and after any appeals are resolved.