FAQs
Basic Information
The Court authorized the Notice because you have a right to know about the proposed Settlements, and your rights and options, before the Court decides whether to approve the Settlements. The Notice explains the lawsuit, the Settlements, and your legal rights. Your legal rights are affected whether you act or do not act.
Chief Judge Matthew W. Brann of the United States District Court for the Middle District of Pennsylvania is presiding over this case. This lawsuit is currently known as In re Geisinger System Services and Evangelical Community Hospital Healthcare Workers Antitrust Litigation, No. 4:21-cv-00196. The people who sued or started the lawsuit are called the “Plaintiffs.” The Plaintiffs are Nichole Leib and Kevin Brokenshire. Geisinger and Evangelical are the “Defendants.”
The lawsuit alleges that Defendants Geisinger and Evangelical made an agreement to not recruit (or “poach”) each other’s Healthcare Workers. The lawsuit also alleges that this agreement reduced competition, made it harder for Healthcare Workers to switch jobs, and allowed Defendants to pay healthcare workers lower compensation than they would have received in an otherwise fully competitive labor market. Geisinger and Evangelical deny the allegations and do not admit any liability related to the allegations as part of this settlement.
You may obtain more information regarding the specific allegations of the action by reviewing the Consolidated Amended Complaint.
In a class action, one or more people called “class representatives” sue on behalf of themselves and other people who have similar claims. Together, all of these people are a “class” or “class members.” In this case, the class representatives are Plaintiffs Nichole Leib and Kevin Brokenshire. One court resolves the issues for all class members, except for those who exclude themselves from the Settlement Class.
For purposes of these Settlements, the Court has certified the Settlement Class (see FAQ 5). This means that if the Court approves these Settlements, they will apply to all members of the Settlement Class (except members of the Settlement Class who exclude themselves).
Plaintiffs and Settlement Class Counsel (“Counsel”) believe that the members of the Settlement Class have been damaged by Defendants’ conduct, as described in the Consolidated Complaint.
The parties agreed to settle this case only after several years of extensive litigation and the close of fact and expert discovery. Plaintiffs and Counsel believe the Settlements are best for all members of the Settlement Class. If the Settlements are approved, Plaintiffs and the Settlement Class will dismiss and release their claims against Defendants and certain other Released Parties (identified in the Settlement Agreements).
Am I Part of the Settlements?
If you received a postcard or email notice, then you are a member of the Settlement Class. But even if you did not, you may be a member of the Settlement Class, as described below.
You are included in the Settlements if you are a person who worked as a Healthcare Worker (see FAQ 6) at Geisinger's or Evangelical's facilities located in Union, Snyder, Northumberland, Montour, Lycoming, and Columbia counties in the Commonwealth of Pennsylvania ("Class Counties") at some point from January 1, 2014 through August 5, 2020.
Excluded from the Settlement Class are members of Geisinger’s and Evangelical’s boards of directors, Geisinger’s and Evangelical’s C-Suite Executives (responsible for day-to-day operation with job titles such as “Chief,” “Executive,” “CMO,” “CNO,” and “President”) and any and all judges assigned to hear or adjudicate any aspect of this litigation and their judicial staff. Also excluded from the Settlement Class is anyone who timely and validly excludes themselves from the Settlement
Class. See FAQ 17.
In this case, healthcare workers are nurses, physicians, advanced practitioners, medical support personnel, and other healthcare professionals. “Other healthcare professionals” include health technicians, therapists, healthcare managers, or other healthcare professionals who contribute to the healthcare system in various capacities.
If you are not sure whether you are a member of the Settlement Class, or have any other questions about the Settlement call the toll-free number, 1-877-543-4579. You may also send questions by mail to the Settlement Administrator at Geisinger System Services, c/o A.B. Data, Ltd., P.O. Box 173108, Milwaukee, WI 53217.
The Settlement Benefits
If the Settlements are approved and become final, they will provide money to members of the Settlement Class. Geisinger will pay $19 million and Evangelical will pay $9.5 million into a Settlement Fund. The total Settlement amount is $28.5 million. If the Settlements are approved by the Court, the Settlement Fund will be used to pay:
- Attorneys’ fees and expenses;
- Notice and administration costs;
- Taxes and tax expenses;
- Service awards to the Class Representatives; and
- Money to eligible members of the Settlement Class
The Geisinger Settlement Agreement and the Evangelical Settlement Agreement are available on the Court Documents on this website page for more information.
Members of the Settlement Class will receive a minimum $250 payment. Additionally, your earnings will be used to determine your pro rata (or proportional) share of the settlement proceeds based on the level of your compensation during the relevant period, after deduction of attorneys’ fees, expenses, litigation costs, taxes, notice and administration costs, service awards to the Class Representatives and allocation of the minimum payment ($250) to Class Members. At this time, it is unknown how much each member of the Settlement Class will receive in a pro rata share. If the Court approves the Settlements and you received a notice by mail or email (or you submitted a valid and timely claim), meet the criteria to be a member of the Settlement Class, and do not opt-out (or exclude yourself) (see FAQ 17), you will receive money from the Settlements.
The amount of money you will receive depends on the number of valid claims and your total compensation at Geisinger and/or Evangelical. At this time, it is estimated that each member of the Settlement Class who is automatically included or submits a valid claim will receive a minimum payment of at least $250, plus a pro rata share of the Settlement Fund based on their total compensation at Geisinger and/or Evangelical.
If there are any funds remaining after all claims are processed and an initial distribution has been made, those funds will be redistributed to eligible members of the Settlement Class or distributed to a non-profit organization, as approved by the Court. No remaining funds will be returned to Geisinger or Evangelical.
Eligible members of the Settlement Class will receive their payments after the Court grants final approval to the Settlements and any appeals are resolved. If there are appeals, resolving them can take time. Please be patient.
Unless you exclude yourself, you will give up your right to separately sue Geisinger and/or Evangelical about the claims in this lawsuit. All of the Court’s decisions will bind you. The Settlement Agreements describe the specific claims you will give up (or “release”), so read it carefully. The Settlement Agreements are available at [website]; paragraph 1(bb) of the Settlement Agreements relate to “Released Claims.” If you have any questions, you can talk to the lawyers listed in FAQ 20 for free, or you can talk to your own lawyer if you have questions about what this means.
How to Get a Payment
If you received a notice by mail or email with a claim number and your total compensation from January 1, 2014 through August 5, 2020 was included in that notice, you are automatically included in the Settlement Class and do not need to submit a Proof of Claim and Release Form in order to receive payment. You are encouraged to use the Unique Identifier and PIN number provided on your notice to verify that your name, address, and work information are correct. However, if you wish to challenge the amount calculated as your total compensation from January 1, 2014 through August 5, 2020, which will be utilized to calculate your pro rata Settlement payment, you will need to contact the Settlement Administrator and provide evidence to support your claim. You must do so by February 17, 2026. If you do not challenge the total compensation communicated to you in the notice, you will automatically receive your Settlement payment based on that calculated compensation and the resulting pro rata share.
Additionally, if your notice reflects in the “How Can I Get a Payment” section that you must complete IRS Form W-9, you must use the Unique Identifier and PIN number provided on your notice to access the online claim portal, verify that your name, address, and work information are correct and submit IRS Form W-9 for tax reporting purposes to receive your Settlement payment. If your notice requires you to complete and submit an IRS Form W-9 but you do not do so, you will not get a Settlement payment. You must do so by February 17, 2026.
If you did not receive a notice by mail or email but believe you are included in the Settlement Class, you may contact the Settlement Administrator by email at info@geisingerevansettlement.com and the Settlement Administrator will attempt to locate your information and provide your Unique ID and PIN. If the Settlement Administrator is unable to locate your records, you will need to complete and submit a Proof of Claim and Release Form. You can download or complete a Proof of Claim and Release Form by going to the "File A Claim" tab on this website. Alternatively, you can request one be sent to you by emailing at info@geisingerevansettlement.com or calling 1-877-543-4579.
You must submit your Proof of Claim and Release Form or review/update your information on this website or by mail postmarked, no later than February 17, 2026.
Claims submitted by mail should be sent to:
Geisinger Evangelical Settlement
c/o A.B. Data, Ltd.
P.O. Box 173108
Milwaukee, WI 53217
After it receives your timely submitted Proof of Release and Claim Form, the Settlement Administrator will decide if your claim is eligible and will use your total compensation to calculate any additional pro rata share of the Settlement on top of the minimum payment of $250 in accordance with terms outlined in FAQ 13 above.
If you are a member of the Settlement Class who received a notice by mail or email that included your total compensation
from January 1, 2014 through August 5, 2020, please review your notice carefully to ensure you are not required to submit an IRS Form W-9 (see FAQ 13 above). You do not need to do anything to receive Settlement payment unless you are required to provide an IRS Form W-9 or want to challenge the total compensation reflected in your email or postcard notice.
You do not have to use a company to file a claim. You can get free help. Some companies may offer to help you file your Claim Form in exchange for a portion of your recovery from the Settlements. While you may choose to use such a company, you should know that you can file with the Settlement Administrator on your own, free of charge. Additionally, you may contact the Settlement Administrator or Counsel (see Question 20) who will help you understand and file your Claim Form—again, at no cost to you.
Yes. This money is taxable. Any money you receive will be treated as wages, subject to applicable tax withholding, and will be reported to the taxing authorities and you on an IRS Form W-2. Any required payroll taxes will be withheld from your payment and paid by the Settlement Administrator. You are required to provide a valid IRS form W-9 as part of the claim filing process. Check with a tax professional if you have any questions.
Excluding Yourself From the Settlements
If you don’t want a payment from these Settlements, but you want to keep the right to sue or continue to sue Geisinger and/or Evangelical on your own about the claims in this lawsuit, then you must take steps to exclude yourself from the Settlements. This is called excluding yourself – or it is sometimes referred to as “opting out.”
To exclude yourself, you must write to the Settlement Administrator by February 17, 2026. Your exclusion request letter must include:
- Your full legal name, address, email and telephone number;
- The unique ID code from your notice (if you have one);
- A statement that you want to be excluded from In re Geisinger System Services and Evangelical Community Hospital Healthcare Workers Antitrust Litigation Settlements;
- A statement that you understand that if you exclude yourself, you will not be able to get any money or benefits from the Settlements with Geisinger and Evangelical under the Settlement Agreements;
- Your (or your officer’s or legal representative’s) signature.
You must mail your exclusion request, so it is received no later than February 17, 2026 to:
Geisinger Evangelical Settlement
c/o EXCLUSIONS
P.O. Box 173001
Milwaukee, WI 53217
No. You will not get a payment if you exclude yourself.
No. Unless you exclude yourself, you give up the right to sue Geisinger and Evangelical for the claims these Settlements resolve.
The Lawyers Representing You
Yes. The Court has appointed attorneys at the firms Cotchett, Pitre & McCarthy, LLP and Berger Montague PC to represent you and the other members of the Settlement Class. These attorneys are called Interim Co-Lead Class Counsel for Plaintiffs and the Proposed Class and Settlement Class Counsel. You may contact Counsel as follows:
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Adam J. Zapala Cotchett, Pitre & McCarthy, LLP 840 Malcolm Road, Suite 200 Burlingame, CA 94010 |
Eric L. Cramer Berger Montague PC I 818 Market Street, Suite 3600 Philadelphia, PA 19103 |
You will not be charged for contacting these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.
To date, Counsel have not been paid any attorneys’ fees or reimbursed for any out-of-pocket costs or expenses that Counsel spent to litigate this case. Any attorneys’ fees and costs and expenses will be awarded only as approved by the Court in amounts determined to be fair and reasonable. By January 20, 2026, Counsel will move for an award of attorneys’ fees not to exceed 33.33% of the settlement fund, plus a proportional share of accrued interest, reimbursement of litigation costs and expenses not to exceed $3,500,000, tax and tax expenses, and a service award of up to $10,000 for each Class Representative ($20,000total) to be paid out of the settlement fund. If the Court grants Counsel’s requests, these amounts would be deducted from the settlement fund. You will not have to pay these fees, expenses, and costs out of your own pocket.
Any motions in support of the above requests will be available on this website after they are filed on January 20, 2026. After that time, if you wish to review the motion papers, you may do so by viewing them on the Court Documents page.
Objecting to the Settlements
You have a right to object to or comment on any part of the proposed Settlements, plan of allocation, and/or the request for attorneys’ fees, expenses, and service awards. The Court will consider your views. You can’t ask the Court to order different Settlements; the Court can only approve or reject the Settlements. If the Court does not approve the Settlements, no Settlement payments will be made, and the lawsuit will continue. If that is what you want to happen, you may object.
To object, you must send a letter to the addresses below that includes the following:
- Your full legal name, address, email and telephone number;
- The unique ID code from your notice (if you have one);
- A statement saying that you object to the Geisinger Settlement, Evangelical Settlement, or both Settlements in In re Geisinger System Services and Evangelical Community Hospital Healthcare Workers Antitrust Litigation, 4:21-cv-00196;
- Proof of membership in the Settlement Class, such as your Geisinger or Evangelical Employee ID or a copy of a Geisinger or Evangelical paycheck or paystub;
- The reason(s) you object;
- Any documents and/or any supporting evidence;
- Your name and address, along with the name and contact information of your lawyer (if you have one);
- A statement of whether you (or your lawyer) intend to appear and speak at the Fairness Hearing; and
- Your (or your officer’s or legal representative’s) signature.
You must mail your objection to the following addresses, received no later than February 17, 2026:
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Court |
Class Counsel |
Administrator |
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Clerk of Court U.S. District Court Middle District of Pennsylvania U.S. Courthouse and Federal Office Building 240 West Third Street, Suite 218 Williamsport, PA 17701 |
Adam J. Zapala Cotchett, Pitre & McCarthy, LLP 840 Malcolm Road, Suite 200 Burlingame, CA 94010 |
A.B. Data OBJECTIONS P.O. Box 173001 Milwaukee, WI 53217
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If you don’t timely and validly submit your objection, your view will not be considered by the Court or any court on appeal. You cannot object by telephone or email.
Yes. Even if you object to the Settlements, you may still be able to get a payment if you are eligible.
Objecting is simply telling the Court that you do not like something about the Settlements.
Excluding yourself is telling the Court that you do not want to be a part of the Settlements. If you exclude yourself, you cannot get a payment from the Settlements. If you exclude yourself, you will also have no basis to object to the Settlements because they no longer affects you.
The Fairness Hearing
The Court will hold a hearing (called a Fairness Hearing) to decide whether to approve the Settlements. You may attend and ask to speak, but you don’t have to.
The Court will hold a hearing on March 16, 2026 at 10:00am in Courtroom 1, before Chief Judge Matthew W. Brann, at the United States District Court for the Middle District of Pennsylvania, Herman T. Schneebeli Federal Bldg. & U.S. Courthouse, 240 West Third Street, Suite 218, Williamsport, PA 17701.
Important! The time and date of the Fairness Hearing may change without additional mailed or published notice. Updated information will be posted on the Home page of this website and noted here in FAQ 25.
At this hearing, the Court will consider whether the Settlements are fair, reasonable, and adequate. If there are objections, the Court will consider them and may listen to people who have objected and asked to speak at the hearing. The Court may also decide whether to award attorneys’ fees and expenses and service awards for the Class Representatives. After the hearing, the Court will decide whether to approve the Settlements. We do not know how long these decisions will take.
No. Counsel will answer questions the Court may have at the Fairness Hearing. But you are welcome to come at your own expense. If you send an objection, you don’t have to come to Court to talk about it. As long as you mailed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.
Yes. If you send an objection regarding the Settlements as described in FAQ 22, you may ask to speak at the Fairness Hearing on your objection. You cannot speak at the hearing if you exclude yourself from the Settlement Class,
If You Do Nothing
If you do nothing, and you fit the description of the Settlement Class, you are automatically a member of the Settlement Class. However, in some scenarios (such as when your compensation amount does not appear on the notice) if you do not file a timely and valid Claim Form, you will not receive any payment from the Settlements. You will be bound by past and future rulings, including rulings on the Settlements, Released Claims, and Releasees.
Getting More Information
The notice is only a summary. More details are in the Settlement Agreements, available on the Court Documents page on this website. If you have questions, you also may contact the Settlement Administrator by writing to Geisinger Evangelical Settlement, c/o A.B. Data, Ltd., P.O. Box 173108, Milwaukee, WI 53217, emailing info@Geisingerevansettlement.com, or calling the toll-free number 1-877-543-4579.
You may also be able to access the Settlement Agreements and other Court documents by (a) accessing the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov, or by visiting the Clerk’s Office, United States District Court, Middle District of Pennsylvania, Herman T. Schneebeli Federal Bldg. & U.S. Courthouse, 240 West Third Street, Suite 218, Williamsport, PA 17701, during its normal operating hours.