Question 1

WHAT IS THE ACTION ABOUT?

Accepted Answer

Plaintiff was involved in an auto accident with a person insured by Unique
Insurance Company. The Action accuses Unique Insurance of violating Illinois law
by sending deceptive, unfair and misleading demands for payment related to
insurance claims. Plaintiff is represented by attorneys in the Action:

Keith L. Gibson, GIBSON LAW GROUP, LLC, 411 North Main Street, Suite 150, Glen
Ellyn, IL 60137. (“Class Counsel.”)

Unique Insurance strongly denies violating any  laws and contends it complied
with all applicable laws.

Question 2

WHAT DOES IT MEAN THAT THE ACTION HAS SETTLED?

Accepted Answer

So far, the Court has made no determination whether Unique
Insurance or Plaintiff is correct on the merits. In the meantime, Plaintiff and
Unique Insurance used Magistrate Judge Sheila M. Finnegan,
an experienced, neutral mediator.

In an effort to resolve the Action by negotiating an to end the case by
agreement (settle the case) rather than continuing the expensive and
time-consuming process of litigation. The negotiations were successful. By
signing a lengthy written settlement agreement (“Agreement”) and agreeing to
jointly ask the Court to enter a judgment ending the Action and enforcing
the Agreement, Plaintiff and Unique Insurance have negotiated a proposed
Settlement that is subject to the Court’s Final Approval. Both sides agree the
proposed Settlement is a compromise of disputed claims. By agreeing to settle,
Unique Insurance does not admit any violations or concede the merit of any
claims.

Plaintiff and Class Counsel strongly believe the Settlement is a good deal for
you because they believe that: (1) Unique Insurance has agreed to pay a fair,
reasonable and adequate amount considering the strength of the claims and the
risks and uncertainties of continued litigation; and (2) Settlement is in the
best interests of the Class Members. The Court preliminarily approved the
proposed Settlement as fair, reasonable and adequate, authorized the Notice, and
scheduled a hearing to determine Final Approval.

Question 3

WHAT ARE THE IMPORTANT TERMS OF THE PROPOSED SETTLEMENT?

Accepted Answer

1. Unique Insurance Will Pay $390,000.00 as the Gross Settlement Amount (Gross
    Settlement). Unique Insurance has agreed to deposit the Gross Settlement
    into an account controlled by the Administrator of the Settlement. The
    Administrator will use the Gross Settlement to pay the Individual Class
    Payments, Class Representative Service Payment, Class Counsel’s attorney’s
    fees and expenses, and the Administrator’s expenses. Assuming the Court
    grants Final Approval, Unique Insurance will fund the Gross Settlement not
    more than [14] days after the Judgment entered by the Court becomes final.
    The Judgment will be final on the date the Court enters Judgment, or a later
    date if Participating Class Members object to the proposed Settlement or the
    Judgment is appealed.
     
 2. Court Approved Deductions from Gross Settlement. At the Final Approval
    Hearing, Plaintiff and/or Class Counsel will ask the Court to approve the
    following deductions from the Gross Settlement, the amounts of which will be
    decided by the Court at the Final Approval Hearing.
    * A. Up to $40% of the Gross Settlement to Class Counsel for attorneys’ fees
      and up to $10,000 for their litigation expenses. To date, Class Counsel
      have worked and incurred expenses on the Action without payment.
    * B. Up to $10,000 as a Class Representative Award for filing the Action,
      working with Class Counsel and representing the Class. A Class
      Representative Award will be the only monies Plaintiff will receive other
      than Plaintiff’s Individual Class Payment.
    * C. Up to $35,000 to the Administrator for services administering the
      Settlement.
      
      Participating Class Members have the right to object to any of these
      deductions. The Court will consider all objections.
       
 3. Net Settlement Distributed to Class Members. After making the above
    deductions in amounts approved by the Court, the Administrator will
    distribute the rest of the Gross Settlement (the “Net Settlement”) by making
    Individual Class Payments to Participating Class Members based on their
    payments to Unique Insurance.
     
 4. Need to Promptly Cash Payment Checks. The front of every check issued for
    Individual Class Payments will show the date when the check expires (the
    void date). If you don’t cash it by the void date, your check will be
    automatically cancelled, and the monies will irrevocably lost to you because
    they will be paid to a non-profit organization or foundation (“Cy Pres”).
     
 5. Requests for Exclusion from the Class Settlement (Opt-Outs). You will be
    treated as a Participating Class Member, participating fully in the Class
    Settlement, unless you notify the Administrator in writing, not later than
    30 days, that you wish to opt-out. The easiest way to notify the
    Administrator is to send a written and signed Request for Exclusion by the
    SEPTEMBER 21, 2026, Response Deadline. The Request for Exclusion should be a
    letter from a Class Member or his/her representative setting forth a Class
    Member’s name, present address, telephone number, and a simple statement
    electing to be excluded from the Settlement. Excluded Class Members (i.e.,
    Non-Participating Class Members) will not receive Individual Class Payments,
    but will preserve their rights to personally pursue a separate claim against
    Unique Insurance. 
     
 6. The Proposed Settlement Will be Void if the Court Denies Final Approval. It
    is possible the Court will decline to grant Final Approval of the Settlement
    or decline enter a Judgment. It is also possible the Court will enter a
    Judgment that is reversed on appeal. Plaintiff and Unique Insurance have
    agreed that, in either case, the Settlement will be void, will not pay any
    money and Class Members will not release any claims against Unique
    Insurance.
     
 7. Administrator. The Court has appointed a neutral company Angeion Group (the
    “Administrator”) to send the Notice, calculate and make payments, and
    process Class Members’ Requests for Exclusion. The Administrator will also
    decide Class Member Challenges regarding mail and re-mail settlement checks
    and tax forms and perform other tasks necessary to administer the
    Settlement. The Administrator’s contact information is contained in Section
    9 [/faqs?id=9] of the FAQs.
     
 8. Participating Class Members’ Release. After the Judgment is final and Unique
    Insurance has fully funded the Gross Settlement and separately paid all
    employer payroll taxes, Participating Class Members will be legally barred
    from asserting any of the claims released under the Settlement. This means
    that unless you opted out by validly excluding yourself from the Class
    Settlement, you cannot sue, continue to sue, or be part of any other lawsuit
    against Unique Insurance or based on the Class Period facts, as alleged in
    the Action and resolved by this Settlement.
    
    The Participating Class Members will be bound by the following release:
    
    All Participating Class Members, on behalf of themselves and their
    respective former and present representatives, agents, attorneys, heirs,
    administrators, successors, and assigns, release Released Parties from any
    and all claims, demands, debts, liabilities, actions, causes of action of
    every kind and nature, obligations, damages, losses, and costs, whether
    known or unknown, actual or potential, suspected or unsuspected, direct or
    indirect, contingent or fixed, that have been, could have been, or in the
    future might be asserted that arise out of or relate to the allegations of
    the Action (the “Released Claims”). “Released Claims” do not include any
    failure by any Party hereto to fully comply with the terms of this
    Agreement. Nothing herein shall be construed as releasing any claim not
    related to the Action.

Question 4

How will the Administrator calculate my payment?

Accepted Answer

Individual Class Payments. The Administrator will calculate Individual Class
Payments by (a) dividing the Net Settlement Amount by the total number of claims
made by all Participating Class Members.

Question 5

How will I get paid?

Accepted Answer

Participating Class Members. The Administrator will send, by U.S. mail, a single
check to every Participating Class Member (i.e., every Class Member who doesn’t
opt-out) who submit valid claims. All claims must be submitted by SEPTEMBER 7,
2026.

Your check will be sent to the same address as the Notice. If you change your
address, be sure to notify the Administrator as soon as possible. Section 9
[/faqs?id=9] of the FAQs has the Administrator’s contact information.

FAQs

About the Action and the Settlement

Your Payment

Excluding Yourself and Objecting

The Final Approval Hearing

Getting More Information

About the Action and the Settlement

1. WHAT IS THE ACTION ABOUT?

2. WHAT DOES IT MEAN THAT THE ACTION HAS SETTLED?

3. WHAT ARE THE IMPORTANT TERMS OF THE PROPOSED SETTLEMENT?

Your Payment

4. How will the Administrator calculate my payment?

5. How will I get paid?

Excluding Yourself and Objecting

6. How do I opt-out of the Class Settlement?

7. How do I object to the Settlement?

The Final Approval Hearing

8. Can I attend the Final Approval Hearing?

Getting More Information

9. How can I get more information?

10. What if I lose my settlement check?

11. What if I change my address?