1. Why did I get a notice?
2. What is this Lawsuit about?
3. Why is this a class action?
4. Why is there a Settlement?
5. How do I know if I am part of the Settlement?
6. What does the Settlement provide?
7. What can I get from the Settlement?
8. How can I get the benefits from this Settlement?
9. When would I get these benefits?
10. What am I giving up if I get benefits under this Settlement?
11. How do I get out of the Settlement?
12. If I don’t exclude myself, can I sue Defendant for the same thing later?
13. If I exclude myself, can I get benefits from this 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 don’t like the Settlement?
17. What’s the difference between objecting and excluding?
18. When and where will the Court decide whether to approve the Settlement?
19. Do I have to come to the hearing?
20. May I speak at the hearing?
21. What happens if I do nothing at all?
22. How do I get more information about the Settlement?
The computer system of QTS was accessed by unknown, unauthorized individuals between September 28, 2021, and October 13, 2021 (the “Data Breach”). During the Data Breach, personal information of approximately 81,355 people may have been accessed and stolen. QTS has identified you as a person who may have been impacted by the Data Breach, and the Court determined that you have a right to know about the proposed Settlement of this class action lawsuit, and about your options, before the Court decides whether to grant final approval of the Settlement. If the Court approves the Settlement, and after any objections and appeals are resolved, the benefits will be distributed to eligible claimants in the way described below.
The notice explains the Lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.
The Court in charge of this case is the United States District Court for the Eastern District of Michigan, and the case is known as Michael Lockridge v. Quality Temporary Services, Inc.,Case No. 4:22-cv-12086. The person who sued is called the Plaintiff. QTS is called the Defendant.
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Plaintiff alleges that QTS did not maintain proper cybersecurity measures, and is therefore responsible for the Data Breach. Defendants deny that they did anything wrong.
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In a class action, one or more people, called Class Representatives (in this case Michael Lochridge), sue on behalf of people who have similar claims. All these people are a Class or Class Members. One court resolves the issues for all Class Members, except for those who exclude themselves from the Class. The United States District Court for the Eastern District of Michigan oversees this class action.
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The Court did not decide in favor of either the Plaintiff or the Defendant. Instead, after numerous documents were exchanged and the Court made rulings on various issues, both sides agreed to a Settlement. By settling, they avoid the cost and uncertainty of a trial. The Class Representative and the attorneys think the Settlement is best for everyone.
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The Court decided that everyone who fits this description is a Settlement Class Member:
All persons Qualified Staffing identified as being among those individuals impacted by the Data Breach, including all who were sent notice of the Data Breach.
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Defendants have agreed to establish a settlement fund of $2,000,000.00. Various costs and fees, which are explained below, will be paid out of the settlement fund. The remaining funds will be distributed to Class Members who timely submit a valid claim. Your portion will depend on type of claim you file and the number of Class Members who timely submit valid claims.
Plaintiff’s attorneys will ask the court to approve fees of up to $600,000.00, and up to $35,000.00 for costs of litigation. Up to now, Plaintiff’s attorneys have not been compensated for the time, or reimbursed for the expense, of litigating this lawsuit.
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The following benefits are available to Settlement Class members who file a valid, timely claim:
You may file a claim to receive some or all of these benefits.
If, after paying out all court approved fees, expenses, and claims, there is money left over in the settlement fund, all Class Members who filed any type of claim will receive a pro rata share of that remaining money.
If, however, the value of the claims is greater than the settlement fund after court-approved fees and expenses have been paid out, then claims will be paid on a pro-rata basis as explained in the Settlement.
Complete information on these benefits and how to receive them can be found on the settlement website at www.QualifiedStaffingDataSettlement.com.
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To receive the benefits described above you must timely submit a valid claim. You may do this by filling out and submitting the Claim Form online here or downloading a copy of the Claim Form here and submitting it by mail. You may also email info@QualifiedStaffingDataSettlement.com or call 833-200-7002 to request that a Claim Form be mailed to you. If you are submitting a paper Claim Form, make sure that all fields are completed, including your full name, mailing address, email address, and contact phone number, and that the declaration is signed and dated.
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The Court will hold a hearing on July 18, 2024 at 2:00 p.m. to decide whether to approve the Settlement. If the Court approves the Settlement, there could be appeals afterward, which will take time to resolve. Please be patient.
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Unless you exclude yourself, you are staying in the Settlement Class, and that means that you can’t sue, continue to sue, or be part of any other lawsuit against Defendant about the legal issues in this case. It also means that all of the Court’s orders will apply to you and legally bind you.
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To exclude yourself from the Settlement, you must submit a Request for Exclusion, which is a written statement clearly stating that you wish to be excluded from the Settlement reached in Michael Lockridge v. Quality Temporary Services, Inc., Case No. 4:22-cv-12086, pending in the United States District Court for the Eastern District of Michigan. The written statement must include your full name, mailing address, telephone number, and email address, and must be dated and physically signed.
Your written request for exclusion must be mailed and postmarked no later than June 25, 2024 to:
You may also email a scanned copy of your written statement to info@QualifiedStaffingDataSettlement.com. You can’t exclude yourself by telephone. If you ask to be excluded, you should not submit a Claim Form, and you cannot object to the Settlement. If you exclude yourself, you will not be legally bound by anything that happens in this Lawsuit. You may be able to sue, or continue to sue, Defendants over these claims in the future.
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No. Unless you exclude yourself, you give up the right to sue Defendants for the claims that this Settlement resolves. If you have a pending lawsuit, speak to your lawyer in that lawsuit immediately. You must exclude yourself from this Settlement Class to continue your own lawsuit. Remember, the exclusion deadline is June 25, 2024.
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No. If you exclude yourself, you cannot receive any of the benefits of this Settlement. However, you may sue, continue to sue, or be part of a different lawsuit against Defendants.
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Yes. The Court has appointed Karl A. Brooke Murphy of Murphy Law Firm and William B. Federman of Federman & Sherwood, as “Class Counsel” to represent you and other Settlement Class Members. 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 ask the Court to approve attorneys’ fees of up to $600,000.00, and expenses of up to $35,000.00. This amount will be paid from the settlement fund. Up to now, Class Counsel have not been compensated for the time, or reimbursed for the expense, of litigating this lawsuit.
Additionally, Class Counsel will ask for a service award of $2,500.00 for Michael Lochridge because he is the Plaintiff who brought this Lawsuit on behalf of all Settlement Class Members. Service awards are commonly granted by the court to recognize the efforts of Plaintiffs in bringing and prosecuting lawsuits on behalf of others.
The cost of administering the Settlement will also be paid from the settlement fund.
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You can tell the Court that you don’t agree with the Settlement, or some part of it. This is called an “objection.” You can give the reasons why you think the Court should not approve the Settlement. The Court will consider your views.
To object, you must send a letter stating that you object to the proposed Settlement in the Lockridge v. Quality Temporary Services, Inc., Case No. 4:22-cv-12086, pending in the United States District Court for the Eastern District of Michigan. Be sure to include your full name, mailing address, telephone number, the specific reasons you object to the Settlement (including copies of any documents on which your objection is based, and any persons you intend to call to testify in support of your objection), and whether you intend to appear at the Final Approval Hearing. Additionally, you must provide proof that you are a member of the Settlement Class, as defined above in question 5. If you have an attorney representing you in connection with this objection, provide their name, address, and telephone number, and state whether they intend to appear at the Final Approval Hearing. Make sure to sign and date your objection. The objection must be postmarked no later than June 25, 2024, and sent to all three of the following:
| COURT | CLASS COUNSEL | DEFENSE COUNSEL |
|---|---|---|
United States District Court for the Eastern District of Michigan600 Church StreetFlint, MI 48502 | William B. FedermanFEDERMAN & SHERWOOD10205 N. Pennsylvania AvenueOklahoma City, OK 73120 A. Brooke Murphy MURPHY LAW FIRM4116 Will Rogers ParkwaySuite 700Oklahoma City, OK 73108 | Claudia D. McCarron Richard M. Haggerty MULLEN COUGHLIN LLC426 W. Lancaster Ave.Suite 200Devon, PA 19333 |
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Objecting is simply telling the Court that you don’t like something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you don’t 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 on July 18, 2024 at 2:00 p.m. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court will listen to people who have asked to speak at the hearing. The Court may also decide how much to pay Class Counsel, and whether to grant the requests for service awards. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take.
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No. Class Counsel will answer questions the Court may have. But you are welcome to come at your own expense if you choose. If you send an objection, you don’t have to come to Court to talk about it. As long as you mailed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.
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You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must send a letter stating that it is your “Notice of Intention to Appear in Michael Lockridge v. Quality Temporary Services, Inc., Case No. 4:22-cv-12086.” You may include the notice in your written objection. Be sure to include your name, telephone number, and mailing address, and sign and date your letter. Your Notice of Intention to Appear must be postmarked no later than June 25, 2024, and be sent to:
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If you do not exclude yourself and do nothing, you will not receive any of the benefits of the Settlement, and will still be bound by the terms of the Settlement.
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The notice summarizes the proposed Settlement. Full details are in the Settlement Agreement and other documents, available Important Documents page of this website. You may also contact the Settlement Administrator at 833-200-7002 or info@qualifiedstaffingdatasettlement.com.
PLEASE DO NOT WRITE OR TELEPHONE THE COURT, THE DEFENDANT, OR THE DEFENDANT’S LAWYERS FOR INFORMATION ABOUT THE PROPOSED SETTLEMENT OR THIS LAWSUIT.
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