Named Plaintiff filed a lawsuit claiming Defendant violated the Fair Labor Standards Act (“FLSA”) and the Illinois Minimum Wage Law (“IMWL”). Named Plaintiff claimed, among other things, that Defendant violated the law by failing to pay its hourly-paid security professionals for the time they spent performing work-related tasks prior to and after the beginning and end of their shifts, while the workers were off-the-clock.

Defendant denies any liability or wrongdoing of any kind associated with the claims alleged by the Named Plaintiff in the lawsuit, and Defendant specifically asserts that its pay practices complied with the FLSA, the IMWL and all other federal and state laws.

The Court has not made any ruling on the merits of the Named Plaintiff’s claims, and no party has prevailed in this action.

The Court has not decided in favor of either side in the case. Instead, both sides agreed to a settlement. In a settlement, both sides avoid the cost and risk of a trial, and the affected current and former Plan participants will get benefits that they would not have received if Plaintiffs had litigated the case and lost. The Plaintiffs and their attorneys think the Settlement is in the best interests for everyone who participated in the Plan during the Class Period. Cerner denies Plaintiffs’ claims of wrongdoing. Cerner is settling the Action solely to avoid the expense, inconvenience, and inherent risk and disruption of litigation.

Settlement Class Members are individuals who worked for Defendant as an hourly-paid security professional during the Class Period of July 26, 2019 through January 5, 2024, who worked at least one week of 39.5 hours or more.

After deductions for (i) settlement administration costs, (ii) payroll taxes (excepting employer-side payroll taxes), (iii) the class representative’s incentive award, and (iv) attorneys’ fees and costs, the total amount of money available to be paid to Settlement Class and FLSA Settlement Collective members under the settlement is approximately $950,000.00. Individual settlement amounts are based upon the number of workweeks of 39.5 hours or more that you worked for Defendant as an hourly-paid security professional during the Class Period of July 26, 2019 through January 5, 2024, and each individual will receive a minimum settlement payment of $50.00.

You are not required to take any action to receive a settlement payment. If you are a Settlement Class member and you do not request to be excluded from the settlement, and if the Court grants final approval of the settlement, you will be mailed a check for your settlement payment, and you will be bound by the release of claims as set forth in Paragraph 6 below. By cashing your settlement check, you also consent to join the FLSA Settlement Collective. If you do not cash your settlement check, you will not release any claims under the FLSA.

You may exclude yourself from the lawsuit and “opt-out” of the settlement by submitting a written Exclusion Statement to the Settlement Administrator at the following address: Universal Protection Settlement P.O. Box 2004 Chanhassen, MN 55317-2004.

Your Exclusion Statement must be postmarked by and mailed to the Settlement Administrator no later than April 5, 2024. The Exclusion Statement must include: (1) your full name, address, email address, and telephone number; (2) the approximate dates of your employment with Defendant; (3) a statement that you request to be excluded from the settlement and understand that you will not be eligible to recover any monies as part of the settlement; and (4) your signature. Individuals who request exclusion from the lawsuit will not be bound by the Settlement Agreement, the release set forth therein, or any further proceedings in the lawsuit. If you do not submit a timely Exclusion Statement to request exclusion from the lawsuit and settlement, (i) you will continue to be included in the 3 lawsuit; (ii) you will be bound by the final order of dismissal in the lawsuit, and (iii) you will be bound by the Settlement Agreement, including the release of claims included therin .

If you are not satisfied with the proposed settlement and if you have not submitted an Exclusion Statement, you may object to the settlement by filing a written objection with the Clerk of the United States District Court for the Southern District of Illinois, 301 W. Main Street, Benton, Illinois 62812, by no later than April 5, 2024. You must also send a copy of your written objection to the Settlement Administrator stated in paragraph 5(b), and to Class Counsel listed in paragraph 8 of your Notice, via First-Class United States Mail, overnight mail, or email, and post-marked on or before the end of the Exclusion Period.

A Final Approval Hearing on the proposed Settlement will be held on May 20, 2024 at 9:30 a.m. before the Honorable Judge Staci M. Yandle, United States District Court for the Southern District of Illinois, 301 West Main Street, Benton, Illinois 62812, to determine whether the settlement should be confirmed and approved as fair, reasonable and adequate (the “Final Approval Hearing”). Without further notice, this hearing may be adjourned from time to time. If you are satisfied with the proposed settlement and if you do not wish to be heard, you need not appear at the Final Approval Hearing.