John Doe and Jane Doe, et al. v. Partners Healthcare System, Inc., et al.

Case No. 1984CV01651-BLS1

The Suffolk Superior Court in the Commonwealth of Massachusetts

Frequently Asked Questions

  1. Basic Information

  2. How will the Settlement Fund be distributed?

    The lawyers for the Settlement Class (“Class Counsel”) will ask the Court to approve the following payments from the Settlement Fund:

    • The costs of providing notice and administration of the Settlement;
    • Service Awards to each of the Representative Plaintiffs, not to exceed $3,500 each, as compensation for their active participation in the case on behalf of the Settlement Class;
    • Class Counsel’s compensation for the time and effort incurred litigating the case, which will not exceed 33% of the Settlement Fund, and costs and expenses they incurred;
    • Payments to Settlement Class Members who file timely and valid claim forms according to the plan of allocation outlined below; and
    • Any residual funds remaining after the payments listed above will be distributed to the Massachusetts Interest on Lawyers’ Trust Accounts ("IOLTA") program, the designated cy pres recipient approved by the Court.
  3. How can I get a Settlement Payment?

    If you are a Settlement Class Member and would like to receive a settlement payment, you must submit a claim form no later than December 15, 2021. You must complete the claim form online by CLICKING HERE.

    If you do not complete and submit a claim form online, you will not receive a payment. Note that for each valid Claim, the payment method will be the Electronic Payment method specified on the claimant’s claim form.

  4. How much will I receive from the Settlement?

    The plan of allocation provides for settlement payments to claimants as follows: The Net Settlement Fund shall be allocated to claimants on a proportional basis up to a maximum distribution of $100 per claimant. If there are insufficient funds to pay claimants $100 based on the number of claimants, the payment to each claimant will be reduced proportionally. For clarity, the maximum settlement payment to be made to any single claimant shall not exceed $100.

  5. When will I be paid under the Settlement?

    If you file a timely and valid claim form and submit required information, the Settlement Administrator will evaluate your claim to confirm your eligibility and your payment amount. The Settlement Administrator will notify you of any deficiencies with respect to your claim, and you will have 21 days after such notice is sent to correct these deficiencies. The Settlement Administrator will then issue a final decision on your claim.

    Payments for valid claims will not be made until after the Settlement is finally approved and all appeals and other reviews have been exhausted.

  6. Do I have a lawyer in this case?

    Yes. The Court has appointed Class Counsel to represent you and other Settlement Class Members. In this case, Class Counsel are Jason “Jay” Barnes and Eric Johnson of the law firm Simmons Hanly Conroy LLC, J. Michael Conley of the law firm Kenney & Conley P.C., Jeffrey A. Koncius and Nicole Ramirez of the law firm Kiesel Law LLP, Stephen M. Gorny and Christopher D. Dandurand of the law firm The Gorny Law Firm P.C., and Amy Gunn and Elizabeth Lenivy of The Simon Law Firm, P.C. If you want to be represented by another lawyer, you may hire one at your own expense.

  7. How will the lawyers be paid?

    The attorneys representing the Settlement Class have not yet received any payment for their legal services or any reimbursement of the costs or out-of-pocket expenses they have incurred. Class Counsel plans to ask the Court to award attorneys’ fees from the Settlement Fund not to exceed 33% of the Settlement Fund, and reimbursement of costs and expenses.

  8. How do I object to the Settlement?

    If you are a Settlement Class Member, you may object to any aspect of the Settlement if you do not think it is fair, reasonable, or adequate. The Court cannot order a larger settlement or award you more based on your individual circumstances; the Court can only approve or deny the Settlement as it is presented. Your completed objection must be submitted no later than December 30, 2021, online, or via postal mail to the following address:

    MA Cookie Settlement, 1650 Arch Street, Suite 2210, Philadelphia, PA, 19103.

    Any objection should be in writing and:

    (a) Clearly identify the case name and number, John Doe and Jane Doe, et al. v. Partners Healthcare System, Inc., et al., Suffolk Superior Court, C.A. No. 1984CV01651-BLS1;

    (b) Include the full name, address, telephone number, and email address of the person objecting; (c) Include the full name, address, telephone number, and email address of the objector's counsel (if the objector is represented by counsel);

    (d) State whether the objection applies only to the objector, to a specific subset of the Class, or to the entire Class, and also state with specificity the grounds for the objection;

    (e) Be verified by an accompanying declaration submitted under penalty of perjury or a sworn affidavit;

    (f) Be accompanied by any legal support for the objection the objector believes applicable;

    (g) Identify all counsel representing the objector who will appear at the Final Approval Hearing, if any;

    (h) Identify a list of all persons who will be called to testify at the Final Approval Hearing in support of the objection, if any;

    (i) Confirm whether the objector intends to appear in person or via Zoom (Meeting ID: 161 7623 4752) and/or testify at the Final Approval Hearing; and

    (j) Provide the objector’s signature and the signature of the objector’s duly authorized attorney or other duly authorized representative, if any.

    Settlement Class Members who fail to submit timely written objections in the manner specified above will waive their right to object to any aspect of the Settlement.

  9. Do I need to attend the Final Approval Hearing?

    No. Class Counsel will answer any questions the Court may have. However, any Settlement Class Member who timely submits an objection has the option to appear and request to be heard at the Final Approval Hearing, either in person or through their counsel. If you choose to make an objection through an attorney or have an attorney appear at the Final Approval Hearing on your behalf, you will be solely responsible for paying that attorney’s fees.

  10. What happens if I do nothing at all?

    If you are a Settlement Class Member and you do nothing, you will not receive any Settlement benefits. You will give up rights to sue the Defendants and/or other released parties, about the legal issues in this case that are released by the Settlement Agreement.

  11. What happens if my contact information changes after I submit a claim?

    If you change your mailing address or email address after you submit a claim form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by calling 866-516-2966 or by writing to:

    MA Cookie Settlement, 1650 Arch Street, Suite 2210, Philadelphia, PA, 19103.

  12. How can I submit a claim on the behalf of a minor?

    If you are a parent or guardian of a class member who is under the age of 18, you can submit a claim form on their behalf. Fill out the claim form with your child’s information and answer the questions as they pertain to your child. Sign your name in the signature box at the bottom of the claim form, indicating you are the parent/guardian of the class member in parentheses. (i.e. John Doe (Parent))

  13. How can I get more information?

    The Notice summarizes the Settlement. It does not describe all of its details. For the precise terms and conditions of the Settlement, please see the Settlement Agreement and related documents. Additional information about the Settlement, including a copy of the Settlement Agreement, may be obtained by:

    • Visiting the Important Documents Page;
    • Contacting the Settlement Administrator toll-free by phone at 866-516-2966 or by email at;
    • Accessing the Court docket in this case through the Court’s electronic records systems system at;
    • Visiting the office of the Civil Clerk of the Court for the Suffolk County Superior Court for the Commonwealth of Massachusetts, 3 Pemberton Square, Boston, MA 02108, between 8:30 am and 4:30 pm, Monday through Friday, excluding Court holidays; or
    • Contact Lead Counsel for the Class, Jason “Jay” Barnes of Simmons Hanly Conroy, by phone at 800-479-9533; by mail at One Court Street, Alton, IL 62002; or by email at

    Please do not telephone the Court or the Civil Court Clerk’s Office to inquire about the Settlement.