1. Why was the Notice issued?
2. What is this lawsuit about?
3. Why is this Lawsuit a class action?
4. Why is there a Settlement?
5. How do I know if I am Included in the settlement?
6. What if I am not sure whether I am included in the settlement?
7. What does the settlement provide?
8. How do I get benefits?
9. Do I need to do anything to remain in the settlement?
10. What am I giving up as part of the settlement?
11. If I exclude myself, can I get a payment from this settlement?
12. If I do not exclude myself, can I sue Cornerstone for the same thing later?
13. How do I exclude myself from the settlement?
14. Do I have a lawyer in this case?
15. How will the lawyers be paid?
16. How, do I tell the Court that I do not like the settlement?
17. What is the difference between objecting and asking to be excluded?
18. When and where will the Court decide whether to approve the settlement?
19. Do I have to attend the hearing?
20. May I speak at the hearing?
21. What happens if I do nothing?
22. How do I get more information?
The Court authorized the 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. The notice explains the legal rights and options that you may exercise before the Court decides whether to approve the settlement.
This matter involves a lawsuit in the United States District Court for the Western District of Missouri (Johnson v. Cornerstone National Insurance Co., Case No. 22-cv-04135). The persons who sued are called the Plaintiffs. Cornerstone is called the Defendant.
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The lawsuit claims that Cornerstone was responsible for allowing the Unauthorized Data Disclosure to occur and asserts claims for violation of the Drivers’ Privacy Protection Act, 18 U.S.C. § 2721, et seq., negligence, negligence per se, violation of the California Consumer Privacy Act, Cal. Civ. Code § 1798.100, et seq., violation of California’s Unfair Competition law, Cal. Bus. & Prof. Code § 17200, et seq., declaratory and injunctive relief, and breach of contract to which Plaintiffs and the Class are third-party beneficiaries. The lawsuit seeks compensation for people to whom Cornerstone sent notice of the Unauthorized Data Disclosure.
Cornerstone denies all of the Plaintiffs’ claims and maintains it did not do anything wrong and that the potential exposure of data did not cause harm to any individuals.
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In a class action, a small number of persons who bring the lawsuit are called the “Representative Plaintiffs” and 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 William Johnson, Joshua Kirk, and Toni Reynolds. One court resolves the issues for all class members, except for those who exclude themselves from the class.
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By agreeing to settle, both sides avoid the cost and risk of a trial, and people who submit valid timely claims will get compensation. The Representative Plaintiffs and their attorneys believe the settlement is fair, reasonable, and adequate and, thus, best for the Settlement Class and its members. The settlement does not mean that Cornerstone did anything wrong.
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You are included in the Settlement Class if Cornerstone sent you notice on or around August 4, 2022 that your personal information was accessed or acquired without authorization in the Unauthorized Data Disclosure. If you did not receive notice of the Unauthorized Data Disclosure or a postcard notice of this Settlement by U.S. mail, but you believe you may be a Settlement Class Member, please email info@CornerstoneDataSettlement.com to verify your identity and membership in the Settlement Class and receive further information on how to file a claim.
Excluded from the Settlement Class are any officer or director of Cornerstone; any officer or director of any affiliate, parent, or subsidiary of Cornerstone; any agent of Cornerstone; and any judge to whom this case is assigned, his or her spouse, members of the judge’s staff, and anyone who requests exclusion from the Settlement Class prior to July 10th, 2025.
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If you are not sure whether you are included in the settlement, you may call 1-(833) 296-0841 with questions or email info@CornerstoneDataSettlement.com. You may also write with questions to Cornerstone Settlement Administrator, PO Box 25244 Santa Ana, CA 92799. Please do not contact the Court with questions.
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The settlement provides that pro rata cash payments to Settlement Class Members who submit timely claims, attorneys’ fees of up to 33.33% of the settlement fund, or $174,982.50, litigation expenses not to exceed $15,000.00, and the costs of notice and settlement administration, estimated to be approximately $145,675.00, will be paid from the $525,000 settlement money.
Settlement Class Members may submit a claim for a cash benefit that, if the Court approves the settlement, will be paid on a pro rata basis, estimated to be between approximately $25 and $78. This estimation is based upon the assumption that between 1% and 3% of Settlement Class Members will file claims. The payment amount may be different, and the amount depends upon how many Settlement Class Members file valid claims. Any funds that remain in the Settlement Fund due to uncashed checks or digital payments will be paid to cy pres recipient Legal Aid of Western Missouri (see https://lawmo.org).
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To get a payment, you must complete and submit a Claim Form. Claim forms may submitted online here. Otherwise, copies of the Claim Forms are available for download here, or you may request one be sent to you by mail by emailing info@CornerstoneDataSettlement.com. Read the instructions carefully, fill out the Claim Form, and submit it via email, or mail it postmarked no later than July 10th, 2025, to:
Cornerstone Settlement Administrator
P.O. Box 25244
Santa Ana, CA 92799
info@CornerstoneDataSettlement.com
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You do not have to do anything to remain in the settlement, but if you want a payment you must submit a Claim Form online or postmarked on or before July 10, 2025.
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If the settlement becomes final, you will give up your right to sue for the claims being resolved by this settlement. You will be “releasing” Cornerstone and all related people or entities as described in paragraphs 27, 28 and 43 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 one of the attorneys listed in Question 14 for free, or you can, of course, talk to your own lawyer at your own expense if you have questions about what this means.
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If you do not want a payment from this settlement, but you want to keep the right to sue Cornerstone about issues in this case, then you must take steps to get out of the Settlement Class. This is called excluding yourself from – or is sometimes referred to as “opting out” of – the Settlement Class.
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.
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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.
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To exclude yourself, send a letter that says you want to be excluded from the settlement in the lawsuit styled Johnson v. Cornerstone National Insurance Co., Case No. 22-cv-04135 in the United States District Court for the Western District of Missouri. Include your name, address, and signature. You must mail your Exclusion Request postmarked by July 10, 2025, to:
Cornerstone Settlement Exclusions
P.O. Box 25244
Santa Ana, CA 92799
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The Court appointed the following lawyers as “Class Counsel”: Kate M. Baxter-Kauf of Lockridge Grindal Nauen P.L.L.P., 100 Washington Avenue South, Suite 2200, Minneapolis, MN 55401, (612) 339-6900; Rachele R. Byrd of Wolf Haldenstein Adler Freeman & Herz LLP, 750 B Street, Suite 1820, San Diego, CA 92101, (619) 239-4599; M. Anderson Berry of Clayeo C. Arnold, A Professional Corp., 865 Howe Ave., Sacramento, CA 95825, (916) 239-4778; Gayle M. Blatt of Casey Gerry Schenk Francavilla Blatt & Penfield, LLP, 110 Laurel Street, San Diego, CA 92101, (619) 238-1811; and Maureen M. Brady of McShane & Brady, LLC, 1656 Washington, Ste. 120, Kansas City, MO 64108, (816) 888-8010.
You will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.
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Class Counsel will request the Court’s approval of an award for attorneys’ fees of up to 33.33% of the settlement fund, or $174,982.50, and reimbursement of reasonable litigation costs and expenses not to exceed $15,000.00. Class Counsel will also request approval of service awards of $2,000.00 for each of the three Representative Plaintiffs. Any amount that the Court awards for attorneys’ fees, costs, expenses, and service awards will be paid from the settlement fund.
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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 with the Court a written objection that includes all of the following:
the name and case number of this Action (Johnson v. Cornerstone National Insurance Co., Case No. 22-cv-04135 (W.D. Mo.));
your name, address and telephone number and, if you are represented by counsel, the name, address and telephone number of such counsel;
a written statement specifically describing all of your objections to the settlement and the reasons for such objections; and
a statement as to whether you or someone on your behalf will attend the Final Approval Hearing.
To be timely, you must file your objection with the Court no later than July 10, 2025. You can file your objection electronically through the Court’s Document Filing System at https://ecf.mowd.uscourts.gov/cgi-bin/ShowIndex.pl, or mail your objection to the Court at: Clerk of Court, Charles Evans Whittaker U.S. Courthouse, 400 E. 9th Street, Kansas City, MO 64106. If you mail your objection to the Court it must be postmarked on or before July 10, 2025, and you must also mail a copy of your objection to Class Counsel (listed in Question 14) on or before July 10, 2025.
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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 Settlement Class. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself, you have no basis to object because the case no longer affects you.
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The Court will hold a Final Approval Hearing at 1:30pm on September 25, 2025, at the United States District Court for the Western District of Missouri, Charles Evans Whittaker U.S. Courthouse, 400 E. 9th Street, Kansas City, MO 64106, to 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 filed a written objection and ask to speak at the hearing. 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 service awards for 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. The hearing may be moved to a different date or time without additional notice, so it is a good idea to check Important Dates for any changes.
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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 file an objection, you do not have to come to the Court to talk about it. As long as you file your written objection on time and according to the instructions provided in Question 16, the Court will consider it.
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You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must file a written objection as described in Question 16 and appear on September 25, 2025.
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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 about the legal issues in this case ever again against Cornerstone or any related people or entities as described in paragraph 28 of the Settlement Agreement. The Settlement Agreement is available here.
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This Website 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:
Cornerstone Settlement Administrator
P.O. Box 25244
Santa Ana, CA 92799
You may also contact Class Counsel listed in Question 14. You can also get a Claim Form here, or by emailing info@CornerstoneDataSettlement.com. Please do not contact the Court for information.
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