Vaughan v. Delta Delta Delta Fraternity


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FREQUENTLY ASKED QUESTIONS





BASIC INFORMATION

The Court authorized the Notice to inform you about a proposed Settlement with Defendants. You have legal rights and options that you may act on before the Court decides whether to approve the proposed Settlement. The Notice explains the lawsuit, the Settlement, and your legal rights.



The case is called Vaughan v. Delta Delta Delta Fraternity, Case No. 1:24-cv-00186-LCB-JEP.



A class action is a lawsuit in which one or more plaintiffs-in this case, Plaintiff and Class Representative Mason Vaughan-sue on behalf of a group of people who have similar claims. Together, this group is called a "Class" and consists of "Class Members." In a class action, the court resolves the issues for all class members, except those who exclude themselves from the class.



THE CLAIMS IN THE LAWSUIT AND THE SETTLEMENT

Plaintiff claims that Defendants failed to implement and maintain reasonable security measures to adequately protect the PII in its possession and to prevent the Data Incident from occurring.



Defendants deny that they are liable for the claims made in the lawsuit and deny any allegations of wrongdoing. More information about the complaint in the lawsuit can be found here.



The Court has not decided whether the Plaintiff or Defendants should win this case. Instead, both sides agreed to this Settlement. That way, they can avoid the uncertainty, risks, and expense of ongoing litigation, and Settlement Class Members will be eligible to get compensation now rather than years later-if ever. The Class Representative and attorneys for the Settlement Class Members, called Class Counsel, agree the Settlement is in the best interests of the Settlement Class Members. The Settlement is not an admission of wrongdoing by the Defendants.



WHO'S INCLUDED IN THE SETTLEMENT?

You are part of the Settlement as a Settlement Class Member if you received a notification letter from Defendants stating that your personal information was or may have been compromised in the Data Incident. Settlement Class Members will have been mailed a notice of their eligibility. If you are still not sure whether you are included, you can contact the Settlement Administrator by calling 1-888-663-3771, by emailing TriDeltaDataSettlement@cptgroup.com, or by reviewing the contents of this website.



This Settlement Class does not include (1) the judges presiding over this Action, and members of their direct families; (2) Defendants, their subsidiaries, parent companies, successors, predecessors, and any entity in which Defendants or their parents have a controlling interest and their current or former officers, directors, and employees; and (3) Settlement Class Members who submit a valid a Request for Exclusion prior to the Opt-Out Deadline.



THE SETTLEMENT BENEFITS

Under the proposed Settlement, Defendants will pay (or cause to be paid) $150,000 into a Settlement Fund. The Settlement Fund, plus interest accrued thereon, will pay notice and administration costs, Court-approved attorneys' fees and costs, Court-approved service awards for class representatives, and certain Settlement Fund taxes and tax expenses (the "Net Settlement Fund"). The Net Settlement Fund will then be used to provide Participating Settlement Class Members with benefits described below.



Credit Monitoring: The Settlement will provide Credit Monitoring Services to all Participating Settlement Class Members. The Credit Monitoring Services include three (3) years of identity theft protection and credit monitoring, which includes identity theft monitoring, alerts, three bureau credit monitoring, fraud resolution, and identity theft insurance coverage for certain costs, identity restoration, and unauthorized electronic fund transfers. The code to enroll in the Credit Monitoring Services was provided in the Notice sent to you. If the Settlement is approved by the Court and becomes final, the Settlement Administrator will activate the codes for the Credit Monitoring Services.



Reimbursement for Lost Time and Out-of-Pocket Losses: If you spent time responding to the Data Incident, you may be eligible to receive compensation for Lost Time. If you incurred financial losses that are fairly traceable to the Data Incident, you may be eligible to receive reimbursement for ordinary out-of-pocket losses.



  1. Attested Time: A claim for reimbursement may also include a claim for up to 4 hours of time spent in response to the Data Incident. Lost Time will be compensated at $25.00/hour. Claims for Attested Time are subject to a $100.00 cap.
  2. Out-of-Pocket Losses: A claim for reimbursement may include, but are not limited to the following provided the expenses were incurred primarily as a result of the Data Incident: (i) unreimbursed costs, expenses, losses or charges incurred as a result of identity theft or identity fraud, falsified tax returns, or other possible misuse of class member's personal information; (ii) costs incurred on or after March 5, 2024, associated with purchasing or extending additional credit monitoring or identity theft protection services and/or accessing or freezing/unfreezing credit reports with any credit reporting agency; and (iii) other miscellaneous expenses incurred related to any Out-of-Pocket Loss such as notary, fax, postage, copying, mileage, and long-distance telephone charges. Claims for reimbursement of Out-of-Pocket Losses can be combined with a claim for Attested Time, but are subject to a $5,000.00 overall cap.
Alternative Cash Payment: In lieu of receiving payment for Attested Time, reimbursement for Out-of-Pocket Losses, or Credit Monitoring Services, Settlement Class members may file a claim for an alternative cash payment estimated at $75.00. If the benefits claimed by all Settlement Class Members meets or exceeds the amount of the Net Settlement Fund, then the payments and/or benefits for your Claim may be reduced pro rata by the Settlement Administrator so that the aggregate cost of all payments and benefits does not exceed the amount of the Net Settlement Fund.

Confirmatory Discovery: Defendants have also agreed to provide documents and information to Class Counsel showing that they have taken data security measures to remedy the issues that led to the Data Security Incident and have implemented other business practices to help ensure information security. Defendant estimates that the costs of these measures are approximately $86,300, which shall be paid by Defendants separate and apart from the Settlement Fund.



HOW TO GET BENEFITS

You do not need to make a claim to receive Credit Monitoring Services under the Settlement. If the Settlement is approved by the Court and becomes final, the Settlement Administrator will activate the codes for the Credit Monitoring Services which is contained on the Notice sent to you.



To qualify for a payment for reimbursement for lost time and/or out-of-pocket losses, or an alternative cash payment, you must complete and submit a Claim Form. Settlement Class Members who want to submit a Claim must fill out and submit a Claim Form here or by mail to the Settlement Administrator. Claim Forms are available here or by calling 1-888-663-3771. All Claim Forms must be submitted no later than February 3, 2025.



The hearing to consider the fairness of the Settlement is scheduled for March 10, 2025, at 2:00 P.M. Eastern Time. If the Court approves the Settlement, the codes for Credit Monitoring Services will be activated and eligible Settlement Class Members whose claims were approved by the Settlement Administrator will be sent payment after all appeals and other reviews, if any, are completed. Please be patient.



THE LAWYERS REPRESENTING YOU

Yes, the Court has appointed Edward Maginnis and Karl Gwaltney of Maginnis Howard as "Class Counsel" to represent you and all class members. You will not be charged for these lawyers. You can ask your own lawyer to appear in Court for you at your own expense if you want someone other than Class Counsel to represent you.



Class Counsel Contact Information
Edward H. Maginnis
Karl S. Gwaltney
MAGINNIS HOWARD
7706 Six Forks Road, Suite 101
Raleigh, North Carolina 27615
emaginnis@maginnishoward.com
kgwaltney@maginnishoward.com
Telephone: 919-525-0450



To date, Class Counsel has not received any payment for their services in conducting this litigation on behalf of the Class and have not been paid for their out-of-pocket expenses. Class Counsel will ask the Court for an award of attorneys' fees and expenses not to exceed one-third of the settlement fund ($50,000.00). Such sums as may be approved by the Court will be paid from the Settlement Fund.



Class Counsel will also request a service award of $2,500.00 for the Plaintiff, to be paid from the Settlement Fund.



The Court will determine the proper amount of any attorneys' fees, costs, and expenses to award Class Counsel and the proper amount of any service awards to Plaintiff.



Class Counsel will file their request for attorneys' fees, costs, and expenses and service awards for Plaintiffs with the Court, which will also be posted here.



YOUR RIGHTS AND OPTIONS

If you do not exclude yourself from the Settlement, you will not be able to sue Defendants about the Data Incident, and you will be bound by all decisions made by the Court in this case, the Settlement, and its included Release. This is true regardless of whether you submit a Claim Form. However, you may exclude yourself from the Settlement (see Question 14). If you exclude yourself from the Settlement, you will not be bound by any of the Released Claims, which are described in the Settlement Agreement here.



If you do nothing, you will still be eligible to receive credit monitoring but will receive no other benefits under the Settlement. You will be in the Settlement Class, and if the Court approves the Settlement, you will also be bound by all orders and judgments of the Court, the Settlement, and its included Release. You will be deemed to have participated in the Settlement and will be subject to the provisions of Question 11 above. Unless you exclude yourself, you won't be able to file a lawsuit or be part of any other lawsuit against Defendants for the claims or legal issues released in this Settlement.



If you exclude yourself from the Settlement, you will receive no benefits under the Settlement. However, you will not be in the Settlement Class and will not be legally bound by the Court's judgments related to the Settlement Class and Defendants in this class action.



You can ask to be excluded from the Settlement. To do so, you must send a written notification to the Settlement Administrator stating that you want to be excluded from the Settlement in Vaughan v. Delta Delta Delta Fraternity, Case No. 1:24-cv-00186-LCB-JEP. Your written notification must include: (1) the name of the proceeding; (2) your full name and current address; (3) your signature; and (4) the words "Request for Exclusion" or a comparable statement that you do not wish to participate in the Settlement at the top of the communication. You must mail your exclusion request, postmarked no later than February 3, 2025, to the following address:



Vaughan v. Delta Delta Delta Fraternity
c/o CPT Group, Inc.
50 Corporate Park
Irvine, CA 92606

You cannot exclude yourself by phone or email. Any individual who wants to be excluded from the Settlement must submit his or her own exclusion request. No group opt-outs shall be permitted. Any Settlement Class Member who does not file a timely Request for Exclusion will lose the opportunity to exclude himself or herself from the Settlement and will be bound by the Settlement.



No. Unless you exclude yourself, you give up any right to sue Defendants for the claims or legal issues released in this Settlement, even if you do nothing.



No. If you exclude yourself, do not submit a Claim Form to ask for any benefits.



If you do not exclude yourself from the Settlement Class, you can object to the Settlement if you do not agree with any part of it. You can give reasons why you think the Court should deny approval by filing an objection. To object, you must mail a written objection to the Settlement Administrator stating that you object to the Settlement in Vaughan v. Delta Delta Delta Fraternity, Case No. 1:24-cv-00186-LCB-JEP.



The objection must be in writing and be personally signed by you. The written objection must include (i) the name of the proceedings; (ii) the Settlement Class Member's full name, current mailing address, and telephone number; (iii) a statement that states with specificity the grounds for the objection, as well as any documents supporting the objection; (iv) a statement as to whether the objection applies only to the objector, to a specific subset of the class, or to the entire class; (v) the identity of any attorneys representing the objector; (vi) a statement regarding whether the Settlement Class Member (or his/her attorney) intends to appear at the Final Approval Hearing; (vii) a statement regarding whether the Settlement Class Member (or his/her attorney) intends to speak at the Final Approval Hearing; (viii) a list of all other matters in which the objecting Settlement Class Member and/or his/her attorney has lodged an objection to a class action settlement; and (ix) the signature of the Settlement Class Member or the Settlement Class Member's attorney.



You must mail your objection to the Settlement Administrator at Delta Delta Delta Fraternity c/o CPT Group, Inc., 50 Corporate Park, Irvine, CA 92606, postmarked no later than February 3, 2025.



Objecting simply means 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 from the Settlement Class 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.



THE COURT'S FINAL APPROVAL HEARING

The Court will hold the Final Approval Hearing on March 10, 2025, at the Courthouse located at Hiram H. Ward Federal Building, 251 N. Main Street, Winston-Salem, NC, 27101, in Courtroom No. 4. The purpose of the hearing is for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness of the proposed Settlement, including those related to the amount requested by Class Counsel for attorneys' fees, costs, and expenses and the service awards to Plaintiff.



The location, date and time of the Final Approval Hearing are subject to change by Court order. Any changes will be posted here or through the Court's publicly available docket. You should check here (link to important dates tab) to confirm the date and time have not been changed.



No. Class Counsel will answer any questions the Court may have. But you are welcome to attend the hearing at your own expense. If you send an objection, you don't have to come to Court to talk about it. If your written objection was filed or mailed on time and meets the other criteria described in the Settlement, the Court will consider it. However, you may appear on your behalf or pay a lawyer to attend on your behalf to assert your objection if you would like.



Yes. If you do not exclude yourself from the Settlement Class, you (or your attorney) may appear and speak at the Final Approval Hearing concerning any part of the proposed Settlement.



GETTING MORE INFORMATION

The Notice summarizes the proposed Settlement. More details are in the Settlement Agreement, which is available here or by writing to the Settlement Administrator at Delta Delta Delta Fraternity c/o CPT Group, Inc., 50 Corporate Park, Irvine, CA 92606.



Phone Number: 1-888-663-3771



Email: TriDeltaDataSettlement@cptgroup.com



PLEASE DO NOT CALL THE COURT OR THE JUDGE WITH QUESTIONS ABOUT THE SETTLEMENT OR CLAIMS PROCESS.