Pharm-Save / Neil Medical Group Data Breach Class Action

Andrea K. Savidge, et al. v. Pharm-Save, Inc. d/b/a Neil Medical Group
Civil Action No. 3:17-CV-00186-CHB-RSE

You can view and download a copy of the Class Notice and Declaration Form here

About the Lawsuit

A lawsuit is pending in the United States District Court for the Western District of Kentucky, Louisville Division (the “Court”)
against Pharm-Save, Inc. d/b/a Neil Medical Group (“Pharm-Save”).

The lawsuit claims that Pharm-Save is liable for the disclosure of employee W-2 forms for tax year 2015 to unknown criminal actors
engaged in a phishing scheme on March 3, 2016, and that liability is based on claims of negligence
and breach of implied contract. These claims are disputed by Pharm-Save.

Class Certification

On March 31, 2025, the Court certified the following defined class of plaintiffs (the “Class”) to pursue common
claims against Pharm-Save in this Class Action:

All persons who … were the victims of the Pharm-Save data security breach that occurred on or about March 3, 2016, wherein their sensitive and personal data was compromised, and who suffered an actual, present injury or who otherwise incurred cost or lost time mitigating the risk of future harm.

Your Rights and Options

Option 1: Become a Member of the Class

If you wish to become a member of the Class, you must complete the attached Declaration and return it
no later than May 15, 2026. Please send back the signed Declaration via the enclosed self-addressed stamped envelope, or scan and email it to Class Counsel.

If you become a member of the Class, you will be permitted to share in any recovery that may occur in the Class Action.
You will be bound by the Court rulings in this case and by any Class judgment, and you will not be able to pursue your own
claims against Pharm-Save regarding the issues in this case.

Class members may retain their own lawyer to represent them and enter an appearance if they so desire.

Option 2: Opt Out of the Class

If you choose to opt-out of the Class, you will not be entitled to any recovery that may occur in this Class Action, but you
will be free to pursue your own individual claims against Pharm-Save at your own cost. However, you will be subject to any
defenses Pharm-Save has to your claims.

If you wish to opt-out of the Class, the Court will exclude you if you mail a written notice postmarked no later than
May 15, 2026 which must include your name, address and signature and a statement that you “wish to opt-out of the Class in Case No. 3:17-CV-186-CHB.”

If You Do Nothing

If you fail to respond by completing the Declaration or if you affirmatively opt-out, you will be excluded from membership
in the Class.

How to Respond

All completed Declarations or Opt-Out Notices must be sent to the following law firm appointed to represent the Class:

Herzfeld, Suetholz, Gastel, Leniski and Wall, PLLC
Attn: Peter Jannace
515 Park Avenue
Louisville, KY 40208
Email: Peter@hsglawgroup.com
Toll-Free: (833) 447 – 4529

Please refer to the official Notice and Declaration for full instructions and required information.

Declaration

The Declaration asks class members, under penalty of perjury, questions related to whether a fraudulent tax return was filed
using your name/SSN after the March 3, 2016 data breach, whether you spent time or money correcting fraud, whether you enrolled
in identity theft coverage, whether you incurred costs or lost time mitigating risk, and whether you suffered any monetary or
economic loss related to the breach.

Contact Class Counsel

If you have questions about the Notice, the Declaration, or the process for participating or opting out, you may contact Class Counsel via one of the methods below, or the “Contact Us” form on the right.