Frequently Asked Questions

BASIC INFORMATION

1. Why have I received a notice?

The Court authorized notice of a proposed settlement in a class action lawsuit entitled Oksana Yegereva, individually and on behalf of all others similarly situated, v. Medical Management Professional Services, Inc., d/b/a/ USA Vein Clinics, pending as Case No. 2023CH01862 in the Circuit Court of Cook County, Illinois (the “Lawsuit”). The settlement would resolve the Lawsuit brought on behalf of the Settlement Class. You are receiving a Notice because you have been identified through Defendant’s records as a Settlement Class Member.

2. What is this lawsuit about?

The named plaintiff, Oksana Yegereva (“Plaintiff”), filed a class action lawsuit alleging that Medical Management Professional Services, Inc. (“Defendant”) used iris-scanning timeclocks for its employees without making the disclosures and receiving the written consent required by the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. (“BIPA”). Defendant denied and continues to deny these allegations. Notwithstanding their disagreements, the Parties have proposed a settlement that, if approved by the Court, will resolve the employees’ claims, including yours, relating to these iris scans.

3. Why is this a class action?

In a class action lawsuit, one or more people called “Class Representatives” (in this case, Oksana Yegereva) sue as a lead plaintiff on behalf of people who have similar alleged claims. These people together are called the “Class” or “Class Members.” The company they sue (in this case, Medical Management Professional Services, Inc.) is called the Defendant. The Settlement will be binding on all Class Members except those who exclude themselves, if the Court gives final approval to this settlement and upon favorable resolution following any appeal to a higher Court.

4. What is the proposed settlement?

Without admitting any fault or liability, and in exchange for a release of all claims relating to the collection of biometric information, Defendant has agreed to make available a Settlement Fund in the amount of $225,000.00 to pay Settlement Class Members, to pay an incentive award to Plaintiff for serving as the “Class Representative,” to pay attorneys’ fees and expenses to Class Counsel, and to pay settlement administration costs. Each Settlement Class Member who does not timely exclude themselves from the settlement will be entitled to a prorated share of the Settlement Fund, after any deductions for an incentive award to the Class Representative, Class Counsel fees and costs, and settlement administration costs.

The Court has preliminarily approved this settlement, subject to a fairness hearing that will occur on May 5, 2025, at 11:00 am at the Cook County Courthouse located at 50 West Washington Street, Chicago, IL 60602 in Room 2402 or via Zoom [Meeting ID: 955 0046 1687 Passcode: 640378].

5. What can I do now? You have three options.

1. Do nothing to be able to receive settlement money. If you want to participate in the settlement and receive a settlement payment, do nothing. A check will be mailed to you if the Court grants final approval of the settlement. If you do nothing, you will stay in the Settlement Class, be bound by any judgment entered by the Court, you will release your claims against Defendant about collection of your biometric information, and you will not be able to be part of another lawsuit for the claims you release.


2. Exclude yourself from the Settlement Class and the settlement. You can exclude yourself from the class action and the settlement by mailing a written request that states you would like to be excluded from the settlement. This request must be postmarked on or before February 24, 2025, and it must list your full name, phone number, current mailing address, the case name and case number Oksana Yegereva v. Medical Management Professional Services, Inc., Case No. 2023CH01862 (Circuit Court of Cook Cty.), and a statement like this or a similar statement: “I hereby request to be excluded from the Settlement Class in theOksana Yegereva v. Medical Management Professional Services, Inc. case, Case No. 2023CH01862, in the Circuit Court of Cook County.” This is the only option that allows you to keep any rights you currently may have to sue the Defendant for the claims released by the Settlement. You must mail your request for exclusion to:

Yegereva v. MMPS
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799



3. Object to the settlement in writing. Objecting is informing the Court you disapprove of the settlement for some reason. If you object to the settlement and wish to file an objection rather than excluding yourself, you must submit your objection in writing to the Clerk of the Circuit Court for Cook County, Illinois, 50 W. Washington, Suite 1001, Chicago, IL 60602. Your objection must be postmarked by February 24, 2025. By the same date, you must also serve copies of your objection and any supporting memoranda or materials to the attorneys for the Settlement Class, Mark Bulgarelli, Progressive Law Group, LLC, 1570 Oak Avenue, Suite 103, Evanston, IL 60201, and to the attorneys for the Defendant, Charles E. Reis, IV, Littler Mendelson, P.C., 600 Washington Ave., Suite 900, St. Louis, MO 63101.
   
   Your objection must be signed under penalties of perjury and must identify (1) your full name, phone number, and current mailing and email address, (2) that you are a Settlement Class Member, (3) all attorneys who assisted you in the preparation and filing of your objection, (4) a list of all other class action cases in which you or your attorneys have submitted an objection to a settlement, (5) a statement of the reasons why you believe the Court should find that the proposed settlement is not fair, reasonable, adequate, and in the best interests of the Settlement Class, (6) any documents or writings that you desire the Court to consider, and (7) a statement indicating whether you intend to appear at the Final Approval Hearing (either personally or through counsel). Further, if you or any of the attorney assisting you in making an objection have objected to any class action settlement where you or your attorney asked for or received any payment in exchange for dismissal of the objection, or any related appeal, without any modification to the settlement, then the objection must include a statement identifying each such case by full case caption and amount of payment received.
   
   If your objection does not comply with these requirements, the Court will strike and disregard your objection. It is not enough to say that you object. You must state the reasons why you believe the Court should reject the settlement. If you hire an attorney in connection with making an objection, that attorney must also file with the court a notice of appearance by the objection deadline of February 24, 2025. Should you choose this Option, you will be solely responsible for payment of any related fees and expenses that you incur or that your attorney incurs on your behalf. If you exclude yourself, you cannot file an objection. If you file an objection, then you may appear at the final approval hearing before Judge Allen Price Walker on May 5, 2025, at 11:00 am at the Cook County Courthouse located at 50 West Washington Street, Chicago, IL 60602 in Room 2402 or via Zoom [Meeting ID: 955 0046 1687 Passcode: 640378].

6. Who represents the Settlement Class?

The Court appointed Plaintiff to be the “Class Representative” and appointed the following law firm as Class Counsel to represent the Settlement Class: Progressive Law Group, LLC, Mark Bulgarelli and Ilan Chorowsky, 1570 Oak Avenue, Suite 103, Evanston, IL 60201, markb@progressivelaw.com.

Class Counsel are working on your behalf; however, you may hire your own lawyer, but you will have to pay that lawyer yourself. At the fairness hearing, Class Counsel will request that the Court approve an award of $7,500.00 to the Class Representative from the Settlement Fund as an incentive award for serving as the Class Representative. Class Counsel will also request that the Court award one-third (33.33%) of the Settlement Fund ($75,000.00) for attorneys’ fees, plus reimbursement of out-of-pocket litigation expenses, to be paid from the Settlement Fund.

7. When will the Court decide whether to approve the settlement?

The Court will hold a hearing to decide whether the proposed settlement is fair and reasonable and should be approved. At that fairness hearing, the Court will hear any objections and arguments about the proposed settlement, including about the attorneys’ fees and expenses requested by Class Counsel and the incentive award requested for the Class Representative. The fairness hearing will take place on May 5, 2025 at 11:00 am at the Cook County Courthouse, 50 West Washington Street Chicago, IL 60602, in Room 2402 or via Zoom [Meeting ID: 955 0046 1687 Passcode: 640378].

You do not need to attend this hearing unless you object. The fairness hearing may be continued to a future date without further notice, and the hearing may be conducted remotely. Any changes to the fairness hearing date or forum will be posted to this Settlement Website. If the Court does not approve the settlement, the litigation will proceed as if no settlement has been attempted. If the settlement is not approved, there is no assurance that the Settlement Class will recover more than is provided in the settlement, or anything at all. If the settlement is approved, payments will be made only after the settlement becomes final.

8. How do I obtain more information?

This description of the litigation is general and does not cover all of the issues and proceedings. If you have specific questions, you may contact the Settlement Administrator by calling 866-675-2716. You may also contact Class Counsel, by mail at Progressive Law Group, LLC, 1570 Oak Avenue, Suite 103, Evanston, IL 60201, by email at markb@progressivelaw.com, or, by calling (312) 787-2717 (Atty. Mark Bulgarelli). Include the case number, your name, your email address, and your telephone number.

To obtain a copy of the Settlement Agreement, the Plaintiff’s Motion for Approval of the Settlement, and other court documents visit the Important Documents page. You may also view documents related to the case by visiting the office of the Clerk of the Circuit Court for Cook County, Illinois, 50 W. Washington, Suite 1001, Chicago, IL 60602, where files relating to this Lawsuit will be available for inspection and copying at your own expense.

Please do not contact the Clerk of the Court, the Judge, or the Judge’s staff, because they cannot answer your questions or give you advice about this settlement.