NorthShore ERISA Settlement

If you are a Former Participant, or a Beneficiary or an Alternate Payee of a Former Participant and you do not have an Active Account in the Plan, you must submit a Former Participant Claim Form by the submission deadline in order to be eligible for a payment under the Settlement. “Former Participant” means a member of the Settlement Class who does not have an Active Account (i.e., a balance greater than $0) as of April 4, 2025.

You can ask the Court to deny approval of the Settlement and/or the Motion for Attorneys’ Fees and Expenses of Class Counsel or the Case Contribution Award to be requested for the Class Representative by filing an objection. You cannot ask the Court to order a different settlement; the Court can only approve or reject the Settlement presented to it. If the Court denies approval, no settlement payments will be sent out and the lawsuit will continue. If that is what you want to happen, you must object. The Court, however, can award less than the amount requested by Class Counsel for attorneys’ fees and expenses or the amount requested for the case contribution award. If the Court does so (because of an objection or in its own discretion) that ruling could affect the timing and/or amount of settlement payments, but any reduction in Class Counsel’s attorneys’ fees and expenses or the Case Contribution Award to be paid to the Class Representative would not otherwise affect the finality of the Settlement.

If you are a Settlement Class Member, you may ask the Court for permission to speak at the hearing. Anyone wishing to appear must state in their written objection that they intend to appear at the Fairness Hearing, at their own expense.

Objectors or their attorneys intending to participate at the Fairness Hearing also must file a notice of intention to participate (and, if applicable, the name, address, and telephone number of the objector’s attorney) with the Court no later than August 25, 2025. Any objectors, or their counsel, who do not timely file a notice of intention to participate in accordance with this Paragraph shall not be permitted to speak at the Fairness Hearing, except for good cause shown.

If you are a Current Participant, or a Beneficiary or Alternate Payee of a Participant and you have an Active Account in the Plan, you do not need to take any action to be eligible to receive the Settlement benefits. If you do nothing, you still will participate in the Settlement, and you will release any claims you may have against Defendants concerning the conduct Plaintiffs allege in their complaint. You may also receive a payment as described above.

If you are a Former Participant, or a Beneficiary or Alternate Payee of a Former Participant and you do not have an Active Account in the Plan, you must submit a Former Participant Claim Form by the submission deadline or you will not receive any of the settlement payments described in the answers to questions 7 and 8 of the Notice. If you do nothing, you will still be bound by the Settlement as described in this Settlement Notice, if the Settlement is finally approved, BUT YOU WILL NOT RECEIVE ANY MONEY UNLESS YOU SUBMIT A FORMER PARTICIPANT CLAIM FORM, SENT TO OR FILED WITH THE COURT BY THE DEADLINE ESTABLISHED BY THE COURT AND STATED IN PARAGRAPH 9 OF THE NOTICE.