On August 12, 2020, Plaintiff filed an action against Defendants, alleging that their administration of the Plan violated ERISA. Since the filing of the action, the Parties engaged in litigation, including investigating the claims and other developments and briefing motions to dismiss. In September 2024, the Parties mediated the action and were ultimately able to reach the terms of the Settlement.

Defendants have denied and continue to deny any wrongdoing or liability and will continue to vigorously defend the lawsuit if the proposed Settlement is not approved.

Records indicate that you are or may be a Current Participant, Former Participant, Beneficiary or Alternate Payee of a Participant or Former Participant, of the Plan at any time on or after August 12, 2014, through and including November 14, 2024 (the “Class Period”).

Defendants have agreed to pay a total of $980,000.00 to the Class Members (“Gross Settlement Amount”). Class Counsel intends to ask the Court to approve up to 33 1/3% of that amount for attorneys’ fees, inclusive of litigation expenses incurred by Class Counsel, as well as Class Representative’s Case Contribution Award not to exceed $7,500 for the Class Representative. The amount that will be available for distribution to Class Members (“Net Settlement Amount”) will be the Gross Settlement Amount minus the amounts used for other approved settlement purposes (Case Contribution Award, Court-approved Attorneys’ Fees and Expenses to Class Counsel, Administrative Expenses, and certain taxes and tax-related costs).

The amount paid to each Current Participant, Former Participant, Beneficiary or Alternate Payee will be determined by a Plan of Allocation subject to Court approval.

As explained below, if you are a Current Participant, or Beneficiary or Alternate Payee of a Participant and you have an Active Account in the Plan, you do not need to take any action in order to receive payment under the Settlement. Payments made to Current Participants, or to Beneficiaries or Alternate Payees of a Participant who have Active Accounts in the Plan shall be made into these persons’ individual investment accounts in the Plan.

If you are a Former Participant, or a Beneficiary or Alternate Payee of a Former Participant and you no longer have an active account in the Plan, you will need to submit a Former Participant Claim Form by the submission deadline in order to receive payment under the Settlement. Payments made to Former Participants, or to Beneficiaries or Alternate Payees of Former Participants who do not have Active Accounts in the Plan may be made either by check or tax-qualified rollover to an individual retirement account or other eligible employer plan.

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 submit a claim to be eligible for a payment under the Settlement. You will receive any payment for which you are eligible automatically in your Plan account. 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 November 14, 2024.

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, and want to receive any monetary benefits from the Settlement, you must submit the Former Participant Claim Form by no later than March 14, 2025. You must mail the Former Participant Claim Form to the address shown on the Form.

A Former Participant Claim Form will be deemed submitted when it is actually received by the Settlement Administrator at the address listed in the Former Participant Claim Form.

Even if you do not submit a Former Participant Claim Form, you will be bound by the Settlement.

No. The Settlement Class has been certified under Federal Rule of Civil Procedure 23(b)(1). Therefore, as a Class Member, you are bound by any judgments or orders that are entered in the lawsuit for all claims that were asserted in the lawsuit or are otherwise included as Released Claims as defined in the Settlement Agreement. If you wish to object to any part of the Settlement, you may (as discussed below) write to the Court and counsel about why you object to the Settlement.

If you are a Settlement Class Member, you can object to the Settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. To object, you must send a letter or other writing saying that you object to the Settlement in Glick. v. ThedaCare, Inc., et al., Case No. 1:20-cv-1236. Your objection must also include: (1) your full name, current address, and current telephone number, and, if represented by counsel, any of your counsel’s names and contact information; (2) a written statement of your objection(s), specifying the reason(s) for each objection, including any supporting evidence, and whether the objection applies only to you, to a specific subset of the Settlement Class, or to the entire Settlement Class; (3) copies of any papers, brief, or other documents upon which the objection is based; (4) a list of all persons who will be called to testify in support of the objection; (5) a list of any other objections to any class action settlements you or anyone acting on your behalf has submitted in any court, whether state, federal, or otherwise, in the United States in the previous five (5) years; and (6) your signature, even if you are represented by counsel.

You must file your objection with the Clerk of the Court for the United States District Court for the Eastern District of Wisconsin, Green Bay Division, Jefferson Court Building, 125 S. Jefferson St., Rm. 102, Green Bay, WI 54301-4541 or by filing in person. Must be filed or postmarked on or before March 3, 2025. See your Notice for complete instructions.