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'19CV2353 LLJM

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JS 44 (Rev. 06/17) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff(For Diversity Cases Only) and One Box for Defendant)

1 U.S. Government 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6 Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and (Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY 480 Consumer Credit of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 861 HIA (1395ff) 490 Cable/Sat TV

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 862 Black Lung (923) 850 Securities/Commodities/190 Other Contract Product Liability 380 Other Personal 720 Labor/Management 863 DIWC/DIWW (405(g)) Exchange195 Contract Product Liability 360 Other Personal Property Damage Relations 864 SSID Title XVI 890 Other Statutory Actions196 Franchise Injury 385 Property Damage 740 Railway Labor Act 865 RSI (405(g)) 891 Agricultural Acts

362 Personal Injury - Product Liability 751 Family and Medical 893 Environmental Matters Medical Malpractice Leave Act 895 Freedom of Information

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation FEDERAL TAX SUITS Act210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 870 Taxes (U.S. Plaintiff 896 Arbitration220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act or Defendant) 899 Administrative Procedure230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRS—Third Party Act/Review or Appeal of240 Torts to Land 443 Housing/ Sentence 26 USC 7609 Agency Decision245 Tort Product Liability Accommodations 530 General 950 Constitutionality of290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION State Statutes

Employment Other: 462 Naturalization Application446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration

Other 550 Civil Rights Actions448 Education 555 Prison Condition

560 Civil Detainee - Conditions of Confinement

V. ORIGIN (Place an “X” in One Box Only)1 Original

Proceeding2 Removed from

State Court 3 Remanded from

Appellate Court4 Reinstated or

Reopened 5 Transferred from

Another District(specify)

6 MultidistrictLitigation -Transfer

8 Multidistrict Litigation - Direct File

VI. CAUSE OF ACTIONCite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII. REQUESTED IN COMPLAINT:

CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint:JURY DEMAND: Yes No

VIII. RELATED CASE(S) IF ANY (See instructions):

JUDGE DOCKET NUMBERDATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

VICKI STASI, SHANE WHITE, and CRYSTAL GARCIA, individually andon behalf of all others similarly situated

Pinellas

Tina Wolfson, AHDOOT & WOLFSON, PC10728 Lindbrook Drive Los Angeles, CA 90024T: 310-474-9111; F: 310-474-8585; E: [email protected]

INMEDIATA HEALTH GROUP CORP.; and DOES 1 through 20,inclusive

28 U.S.C. § 1332(d); 28 U.S.C. §1332(d)(2)(A)

Negligence, Negligence Per Se, Breach of Contract, Violation of CA's Confidentiality of Medical Information Act.

5,000,000.00

12/09/2019 /s/ Tina Wolfson

X

X X

I I

X

I

X

X

X

'19CV2353 LLJM

Case 3:19-cv-02353-JM-LL Document 1-1 Filed 12/09/19 PageID.25 Page 1 of 2

JS 44 Reverse (Rev. 06/17)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers asrequired by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, isrequired for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk ofCourt for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, useonly the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving both name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, notingin this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X" in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box 1 or 2 should be marked.Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark thissection for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.Original Proceedings. (1) Cases which originate in the United States district courts.Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.When the petition for removal is granted, check this box.Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date.Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict litigation transfers.Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket. PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to changes in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.



Re: Notice of Data Security Incident

Dear ,

I am writing on behalf of Inmediata Health Group, Corp., (Inmediata) to inform you of a data security incident that may have resulted in the potential disclosure of your personal and medical information. At Inmediata, we take the security of all patient information very seriously, and sincerely apologize for any inconvenience this incident may cause. This letter contains information about steps you can take to protect your information and resources we are making available to you.

What Happened? In January 2019, Inmediata became aware that some of its member patients’ electronic patient health information was

of an internal website we use for our business operations. When we became aware of the incident, we immediately

information that may be involved in this incident has been misused. However, out of an abundance of caution, we are informing you about the incident and providing you with information and resources to assist you.

What information was involved?The information potentially impacted by this incident may have included your name, address, date of birth, gender, and medical claim information including dates of service, diagnosis codes, procedure codes and treating physician. Please

What We Are Doing. As soon as we learned about the incident, we took the steps described above. In addition, we are providing you with information about steps you can take to help protect your personal information. Also, we have taken steps to remove

our system and the information we store is secure.

What You Can Do.

As stated above, while we are not aware of the misuse of any information potentially involved in this incident, you can follow the recommendations included with this letter to protect your personal information.

For more information.We sincerely regret any inconvenience or concern that this matter may cause you and remain dedicated to protecting all

Eastern Time if you have questions about this event.

Sincerely,

Mark RiegerCEOInmediata

<<Address1>><<Address2>><<City>>, <<State>> <<Zip>>

April 22, 2019


STEPS YOU CAN TAKE TO FURTHER PROTECT YOUR INFORMATIONReview Your Account Statements and Notify Law Enforcement of Suspicious Activity: As a precautionary measure, we recommend that you remain vigilant by reviewing your account statements and credit reports closely. If you detect

account is maintained. You also should promptly report any fraudulent activity or any suspected incidence of identity theft to proper law enforcement authorities, your state attorney general, and/or the Federal Trade Commission (FTC).

Copy of Credit Report: You may obtain a free copy of your credit report from each of the three major credit reporting

You also can contact one of the following three national credit reporting agencies: TransUnion Experian Equifax Free Annual Report

Fraud Alert: You may want to consider placing a fraud alert on your credit report. An initial fraud alert is free and will

and requests that the creditor contact you prior to establishing any accounts in your name. To place a fraud alert on

at http://www.annualcreditreport.com.

Security Freeze:opened in your name without the use of a PIN number that is issued to you when you initiate the freeze. A security freeze is designed to prevent potential creditors from accessing your credit report without your consent. As a result, using a security freeze may interfere with or delay your ability to obtain credit. You must separately place a security

utility bill, bank statement or insurance statement.

Additional Free Resources: You can obtain information from the consumer reporting agencies, the FTC or from your respective state Attorney General about steps you can take toward preventing identity theft. You may report suspected identity theft to local law enforcement, including to the FTC or to the Attorney General in your state. Residents of Maryland, North Carolina, and Rhode Island can obtain more information from their Attorneys General using the contact information below. Federal Trade Commission Maryland Attorney General North Carolina Rhode Island

Attorney General Attorney General

to dispute incomplete or inaccurate information, and to have consumer reporting agencies correct or delete inaccurate,

Personal Information of a Minor: You can request that each of the three national credit reporting agencies perform a manual search for a minor’s Social Security number to determine if there is an associated credit report. Copies of

report and immediately report any fraudulent accounts to the credit reporting agency. You can also report any misuse of minor’s information to the FTC at https://www.identitytheft.gov/. For more information about Child Identity Theft and instructions for requesting a manual Social Security number search, visit the FTC website: https://www.consumer.ftc.gov/


Re: Notice of Data Security Incident

Dear ,

I am writing on behalf of Inmediata Health Group, Corp., (Inmediata) to inform you of a data security incident that may have resulted in the potential disclosure of your personal and medical information. At Inmediata, we take the security of all patient information very seriously, and sincerely apologize for any inconvenience this incident may cause. This letter contains information about steps you can take to protect yourself and resources we are making available to you.

What Happened? In January 2019, Inmediata became aware that some individuals’ electronic patient health information was available

we use for our business operations. When we became aware of the incident, we immediately deactivated the website

involved in this incident has been misused. However, out of an abundance of caution, we are informing you about the incident and providing you with information and resources to assist you.

What information was involved?The information potentially impacted by this incident may have included your name, address, Social Security number, date of birth, gender, and medical claim information, including dates of service, diagnosis codes, procedure codes and

What We Are Doing. As soon as we learned about the incident, we took the steps described above. In addition, we are providing you with information about steps you can take to help protect your personal information. We also have taken steps to remove

our system and the information we store is secure.

What You Can Do. While we do not believe any patient personal information was at risk, you can follow the recommendations included with this letter to protect your personal information. In addition, as a precautionary measure to safeguard your

Monitoring, Fraud Consultation, and Identity Theft Restoration.

Visit my.idmonitoringservice.com to activate and take advantage of your identity monitoring services.You have until July 31, 2019 to activate your identity monitoring services.Membership Number: <<Member ID>>

services is included with this letter.

<<Address1>><<Address2>><<City>>, <<State>> <<Zip>>

April 22, 2019


For more information.We sincerely regret any inconvenience or concern that this matter may cause you and remain dedicated to protecting

Sincerely,

Mark Rieger

Inmediata


STEPS YOU CAN TAKE TO FURTHER PROTECT YOUR INFORMATIONReview Your Account Statements and Notify Law Enforcement of Suspicious Activity: As a precautionary measure, we recommend that you remain vigilant by reviewing your account statements and credit reports closely. If you detect

theft to proper law enforcement authorities, your state attorney general, and/or the Federal Trade Commission (FTC).

Copy of Credit Report:

TransUnion Experian Equifax Free Annual Report

Fraud Alert:

and requests that the creditor contact you prior to establishing any accounts in your name. To place a fraud alert on

at http://www.annualcreditreport.com.

Security Freeze:opened in your name without the use of a PIN number that is issued to you when you initiate the freeze. A security freeze is designed to prevent potential creditors from accessing your credit report without your consent. As a result,

utility bill, bank statement or insurance statement.

Additional Free Resources:

identity theft to local law enforcement, including to the FTC or to the Attorney General in your state. Residents of Maryland, North Carolina, and Rhode Island can obtain more information from their Attorneys General using the contact information below. Federal Trade Commission Maryland Attorney General North Carolina Rhode Island600 Pennsylvania Ave, NW 200 St. Paul Place Attorney General Attorney General

to dispute incomplete or inaccurate information, and to have consumer reporting agencies correct or delete inaccurate,

Personal Information of a Minor:a manual search for a minor’s Social Security number to determine if there is an associated credit report. Copies of

of minor’s information to the FTC at https://www.identitytheft.gov/. For more information about Child Identity Theft and instructions for requesting a manual Social Security number search, visit the FTC website: https://www.consumer.ftc.gov/


TAKE ADVANTAGE OF YOUR IDENTITY MONITORING SERVICESYou’ve been provided with access to the following services1 from Kroll:

Single Bureau Credit MonitoringYou will receive alerts when there are changes to your credit data—for instance, when a new line of credit is applied for in your name. If you do not recognize the activity, you’ll have the option to call a Kroll fraud specialist, who can help you determine if it’s an indicator of identity theft.

Fraud Consultation

and interpreting how personal information is accessed and used, including investigating suspicious activity that could be tied to an identity theft event.

Identity Theft Restoration

related issues. You will have access to a dedicated investigator who understands your issues and can do most of the work for you. Your investigator can dig deep to uncover the scope of the identity theft, and then work to resolve it.

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ClassAction.orgThis complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Class Action Filed in Wake of January 2019 Inmediata Health Group Data Breach

https://www.classaction.org/news/class-action-filed-in-wake-of-january-2019-inmediata-health-group-data-breach

Documents

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