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Class action settlement

THE ANIMAL DOCTOR, LTD. PROFIT SHARING PLAN LITIGATION

Paszkiet v. The Animal Doctor, LTD., et al Case No. 1:24-cv-840United States District Court for the Northern District of Illinois

Notice of proposed settlement

Your legal rights may be affected

Please read this notice carefully and completely.

If you are a member of the Class, the settlement will affect your legal rights.

A federal court has authorized this notice.

This is not a solicitation from a lawyer.

You have not been sued.

Notice

Notice of Class Action

The parties to this class action have reached a proposed settlement and the Court has certified the Class for settlement purposes and preliminarily approved the Settlement. The Settlement requires Defendants to pay $500,000 into Settlement Fund, which after deducting court-approved payments, will be paid to Class Members (participants or beneficiaries entitled to an immediate payment) based on the amount of their alleged losses in The Animal Doctor, LTD. Profit Sharing Plan (the “Plan”). This notice summarizes the Settlement and informs Class Members of their rights under the Settlement.

Your choices

Your rights and options

SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS

OPTION #1:
DO NOTHING

If you received this Notice by mail or email, you have been identified as a Class Member and if you are entitled to payment, you will receive a payment from this Settlement either paid into the Plan or directly to you depending on your status and any distribution options available to you (see the distribution options below).

OPTION #2:
CHOOSE THE FORM OF
DISTRIBUTION

The manner in which your payment is paid depends on your status in the Plan and whether you are a current employee, former employee with an account in the Plan, a former employee who previously took a full distribution of your account or a beneficiary. If you are entitled to a distribution from the Plan, you need to submit a distribution form to receive a payment to you (or another tax-favored retirement account). If you are entitled to a distribution and want to receive a distribution, you must submit a distribution form within 90 days after the election distribution form is sent to you. If you are a former employee without a current account in the Plan or a beneficiary entitled to payment, and you do NOT timely submit a distribution form, your share of the settlement will be paid by check (for which you may owe taxes).

OPTION #3:
SUBMIT A
CHALLENGE

If you believe that the data about your account is incorrect OR you believe
that you are a Class Member but the notice was not mailed or emailed to you can explaining why the data needs to be corrected by November 30, 2026.

OPTION #4:
OBJECT

If you are not satisfied with the terms of the proposed Settlement, then you or your attorney may send a letter or written statement to the Court at the address listed below by November 30, 2026.

YOU ARE ABLE TO CHOOSE MORE THAN ONE OPTION: If you object, you may still request a distribution.

At a glance

Important dates

08/27/2026

Preliminary Approval

10/01/2026

Initial Mailing Date

11/30/2026

Response Deadline

12/17/2026

Final Fairness Hearing

9:00 a.m.

Need to know

Frequently asked questions

BASIC INFORMATION4 questions
1. Why Did I Get This Notice?

You received this Notice because the Court ordered that notice be provided to Class Members as defined by the Court. You were identified as a potential class member from records produced by The Animal Doctor, LTD. (“Animal Doctor”). The purpose of this Notice is to provide you with information about the Settlement and your rights, including your right to object to the Settlement before the Court decides whether to approve the Settlement.

2. What is This Case About?

The Complaint alleges that Defendants The Animal Doctor, LTD. and Dr. Lori W. Wyatt violated the Employee Retirement Income Security Act of 1974 ("ERISA"), the federal law that governs retirement plans offered by private employers, in connection with the investment of the assets of the The Animal Doctor Profit Sharing Plan (the "Plan") and the administration of the Plan. The Complaint alleges that Defendants breached their ERISA fiduciary duties by investing the Plan’s assets in undiversified assets in 2021 and the Plan’s investments lost a significant amount of its value since that time. Defendants deny any wrongdoing or liability, or that they violated ERISA, and deny that Plaintiff or the Plan suffered any losses. The Court has not ruled on the merits in this case.

A complete description of the claims is contained in the Complaint, along with other important documents, is available on the documents tab: Documents Link

3. What Is a Class Action?

A class action is a lawsuit in which the claims and rights of many people are decided in a single court case. One or more representatives known as “class representatives” file a lawsuit asserting claims on behalf of the entire class. The Class Representative in this case is Cathy Paszkiet, a former employee who is a participant in the Plan and still has an account in the Plan.

A complete description of the claims is contained in the Complaint, along with other important documents, is available on this link: Documents Link

4. Who is a Member of the Class?

The Court certified the Class as follows:

Participants in The Animal Doctor, Ltd. Profit Sharing Plan at any time between March 8, 2021 to December 31, 2025 (except those participants who terminated without even partial vesting) and the beneficiaries of any such participants, excluding the Excluded Persons.

Excluded from the Class are: (1) Defendants, (2) any fiduciaries of the Plan, (3) other persons who had decision-making or administrative authority relating to the administration, investment allocation, modification, funding, or interpretation of the Plan, (4) the beneficiaries of such persons, the immediate relatives of such persons, and (5) the legal representatives, assigns or successors in interest of any excluded person.

THE PROPOSED SETTLEMENT7 questions
5. What Are the Terms of The Settlement Agreement?

The Settlement requires Defendants to pay $500,000 (the “Settlement Amount”) into a Qualified Settlement Fund to resolve all the claims in the Complaint on behalf of the Class against Defendants. Based on the data provided about the Plan’s investments, this represents approximately __ of the losses based on Class Counsels’ calculations. After deduction of any Court-approved attorneys’ fees and costs and any Court-approved service award to the Class Representative, the remaining amount, called the Net Settlement Amount, will be distributed to the Class pursuant to a Court-approved distribution formula called the “Plan of Allocation.”


The Settlement Agreement also requires Defendants to adopt an agreed-upon investment policy to govern the management and diversification of Plan investments. The Settlement requires compliance with that investment policy for one year after the Final Approval Order becomes nonappealable;however, nothing in the Settlement Agreement precludes The Animal Doctor from terminating the Plan. A copy of the Investment Policy is available upon request by Class Members directed to Class Counsel.

6. What Will Be My Share of the Settlement?

TheNetSettlementAmount--theClassSettlementAmountminusCourt-approveddeductionsfor attorneys’fees, expenses, and service award, -- will be divided among Class Members according to a court-approved Plan ofAllocation. Class Counsel’s proposed Plan ofAllocation, which the Courthaspreliminarilyapproved,providesthattheNetSettlementAmountwillbedividedamong ClassMembersbasedontheirproratalossestotheparticipant’sPlanaccount.Thelossesarebased on an the amount of lost earnings a compared to what Class Counsel considered to have been a prudent investment of the Plan’s assets.The Plan ofAllocation as preliminarily approved by the Court can be found at: Documents Link

If you have questions about what is listed on your individualized addendum to this Notice, or believe that you qualify as a Class Member (but didn’t receive a personalized notice), you can contact the SettlementAdministrator at the address below. You must do so by or before November 30, 2026.

If you have questions about what is listed on your individualized addendum to this Notice, or believe that you qualify as a Class Member (but didn’t receive a personalized notice), you can contact the Settlement Administrator at the address below. You must do so by or before [date].

7. How Do I Receive My Share of the Settlement?

The manner in which Class Members receive payment depends on your status in the Plan.

Current Employees: If you are current employee of The Animal Doctor, your share of the Settlement will be paid into the Plan. If you are entitled to a distribution under the terms of the Plan while employed, you can submit an election distribution form. If you later become entitled to a distribution under the terms of the Plan, you can request a distribution at that time.

Former Employees WITH a Current Account in the Plan: If you are a former employee who still has an account in the Plan, your share of the Settlement will be paid into the Plan. You are entitled to submit a request for distribution under the terms of the Plan. The Plan Administrator will send you a distribution election form after the Final Approval Order is entered. If you submit your request for distribution within 90 days when that election distribution form is sent, your settlement payment will be paid to you and you can request that the amount be paid to another tax- qualified retirement account (e.g. an IRA or retirement plan). If you do not timely submit a request for distribution now, you are entitled to request a distribution later and receive a payment of your account in the Plan.

Former Employees WITHOUT a Current Account in the Plan: If you are a former employee who still has an account in the Plan, how your share of the Settlement will be paid depends on what you do.

  • Option #1: Request a Distribution From the Plan. The Plan Administrator will send you a distribution election form after the Final Approval Order is entered. To request a distribution from the Plan, you must submit a distribution election form within 90 days after that election distribution form is sent. If you timely submit a properly completed election form, your share of the settlement will be paid to you through the Plan and you can request that the amount be paid to another tax-qualified retirement account (e.g. an IRA or retirement plan).
  • Option #2: Receive a Check Directly Paid to You: If you do not timely submit a properly completed election form by the deadline, then your share of the settlement will be paid by check from the Settlement Fund to your last known address. If you do not cash the check within the time specified on the check, your share of settlement proceeds may be forfeited.

Beneficiaries. If you are a beneficiary, you are only entitled to a payment if you are entitled to a distribution under the Plan (e.g. a QDRO or because of the death of the participant). All other beneficiaries will not receive a payment from this settlement. If you are a beneficiary entitled to a payment, how your share of the Settlement will be paid depends on what you do.

  • Option #1: Request a Distribution From the Plan. To request a distribution from the Plan, you must submit a distribution election form by [INSERT]. If you timely submit a properly completed election form, your share of the settlement will be paid to you through the Plan and you can request that the amount be paid to another tax-qualified retirement account (e.g. an IRA or retirement plan).
  • Option #2: Receive a Check Directly Paid to You: If you do not timely submit a properly completed election form by the deadline and there is no associated account in the Plan, then your share of the settlement will be paid by check from the Net Settlement Fund to your last known address. If you do not cash the check within the time specified on the check, your share of settlement proceeds may be forfeited.

For All Class Members Entitled a Settlement Distribution: The Plan Administrator will send you a distribution election form after the Final Approval Order is entered. If you do not receive an Election Distribution Packet, you may access it at Documents Link. Defendants will use their reasonable best efforts to ensure that the Settlement will not adversely affect the tax-qualified status of the Plan and that the distributions from the Settlement Amount paid to Class Members qualify for tax- deferred treatment, but they will not and do not guarantee any such result. Defendants will be

responsible for all costs associated with any steps that they undertake to facilitate the tax favored treatment of the Settlement Payment into the Plan and the continued tax qualification of the Plan with respect to the Settlement. This Notice is not intended to provide tax advice. Class Members should consult their own tax advisor regarding any tax consequences of receiving settlement proceeds.

8. What Do I Give Up As a Result of the Settlement?

In exchange for the settlement payment, each Class members, as a participant or beneficiary in the Plan, will release (i.e. give up) any and all claims against Defendants (and related persons) alleged in the Complaint and other claims arising from the same factual basis. The full terms of the Settlement, including the release, are available at Documents Link. If the Settlement is approved, the Court will enter an order dismissing with prejudice all claims against the Defendants and preventing any Class Members from suing Defendants in the future on the released claims.

Defendants have agreed to release certain claims against Plaintiff, the Class and Class Counsel as set forth in Section XIII of the Settlement Agreement.

9. Can the Settlement Be Terminated?

The Settlement may be terminated on several grounds, including if (1) the Court does not approve the terms of the Settlement, (2) the Court does not certify at least one claim on behalf of the Class defined above, (3) the Excluded Persons receive any allocation of the Settlement, (5) the Court permits Class Members to opt out of the Settlement (6) the Class Account Data on which the Settlement was based is not materially correct, (7) the Independent Fiduciary does not issue an opinion that the settlement is not a prohibited transaction under ERISA, or (8) if there is a departure from the agreed investment policy before the Final Approval Order becomes non-appealable. If any of these occurs and one of the Parties exercises his/her/its right to withdraw, the lawsuit will proceed as if the Settlement had not existed. The Settlement will not be final until after the Court has granted final approval of the settlement and any appeals have been resolved or the time that all appeals has ended. The earliest that the Settlement will be final is 30 days after the Final Approval Hearing, but it may be later than that depending on how long after the Court enters the order and judgment or whether someone files an appeal.

10. When Can I Get My Money From the Settlement?

No payments can be made to Class Members until after Final Approval has been entered, the time for appeals has expired and certain administrative tasks have been completed. The time for payments could take several months after Final Approval (even if there are no objections or appeals). The Settlement Administrator will update the website when there are updates. Calls and emails to Class Counsel (or the Settlement Administrator) inquiring when payment will be made only slows down the progress of distribution. Your patience is appreciated.

11. Why Did the Parties Reach This Settlement?

In deciding to settle the lawsuit, Class Counsel reviewed relevant documents, including the investments of the Plan, and assessed the potential monetary remedy in the case. Plaintiff and Class Counsel also considered the strength of the claims and defenses and arguments by Defendants, the expense, length and likely delay of further litigation, the risks arising from the existence of unresolved questions of law and fact, and the risk of whether all claims would proceed on behalf of the Class.

If the parties had not reached a settlement, the Court may not have certified a Class and/or may have found in favor of Defendants and if Defendants had prevailed on their defenses, then the Class could have recovered nothing. Even if Plaintiff succeeded, the Court could have found that any losses that Defendants caused were less than the amount paid in this Settlement. Of course, if Plaintiff prevailed, Defendants may have been liable for more than the Settlement Amount.

In 2025 and in 2026, the parties participated in two separate settlement conferences with a Magistrate Judge. The Settlement was reached as a result of those conferences. The Settlement is a compromise of disputed claims. Defendants dispute the claims in the lawsuit and asserted various defenses. All parties determined that given the uncertainty and risks inherent in litigation, it is best to settle the case on the terms set forth in the Settlement Agreement.

This is only a summary of the Settlement. The full settlement agreement is available at Documents Link, and it on file with the Court.

THE LAWYERS REPRESENTING THE CLASS2 questions
12. Who Are the Lawyers Representing the Class?

The Court has appointed the following lawyers at the following firms as counsel for the Class who have significant experience representing employees/participants in ERISA litigation:

Co-Lead Class Counsel

R. Joseph Barton
THE BARTON FIRM LLP
1633 Connecticut Avenue NW, Suite 200
Washington, DC 20009
Telephone: (202) 734-7046
Animaldoctor@thebartonfirm.com

Michael Bartolic BARTOLIC LAW
180 W. Washington, Suite 700
Chicago, IL 60602
Telephone: (312) 635-0948
michael@bartoliclaw.com

13. How Will the Lawyers be Paid?

Class Counsel have worked on this case for more than two years and have not yet been paid for their time. In prosecuting this case on behalf of the Class, Class Counsel investigated the facts, prepared complaint, engaged in discovery, reviewed documents produced in discovery, participated in settlement conferences and subsequent negotiations. To date, Class Counsel have expended over [ ] hours in this case and have advanced over $[ ] in out-of-pocket expenses on behalf of the Class. Class Counsel will apply to the Court for an award of fees, not to exceed one- third of the Settlement Fund. Class Counsel will also seek reimbursement of their actual costs and expenses, which are not expected to exceed $[ ], plus settlement administration expenses
that are expected to be $4,823.76. Class Counsel will request that the Class Representative receive a service award of $5,000 for her time and efforts in bringing this claim and obtaining the benefits of the settlement for the class. The motion for attorneys’ fees and costs and any motion for a service award will be posted on the Settlement website at Documents Link.

Any Class Member who objects to the request by Class Counsel for payment of these attorneys’ fees and costs or the request for a class representative payment may state that objection in writing and may appear at the hearing, as set forth below. If you submit a written objection, you are not required to appear at the hearing.

HOW TO PROCEED2 questions
14. How Do I Tell the Court What I Think About the Settlement?

Any Class member can comment on the Settlement or tell the Court that you do not agree with any part of the Settlement, the Plan of Allocation or the request for attorneys’ fees, expenses or service award. Any written objections must be sent to Class Counsel at the addresses listed above and must be postmarked no later than November 30, 2026 and sent the Court at this address:

Office of the Clerk
Everett McKinley Dirksen U.S. Courthouse
219 South Dearborn Street
Chicago, IL 60604

Be sure to refer to Paszkiet v. The Animal Doctor, LTD., et al, Case No. 1:24-cv-08403. Include your full name, address, telephone number, signature, and a full explanation of all the reasons you object to the Settlement, including any supporting papers and arguments. You or your attorney must sign the written objection.

If you have no objection to the Settlement, or the request for attorneys’ fees, then you do not need to send any papers to the Court.


15. Can I Opt Out of the Class?

No. You do not have the right to exclude yourself from the Class or the Settlement. The Lawsuit was certified as a mandatory (“non-opt-out”) class action. As a Class Member, you will be bound by any judgments or orders that are entered in the Lawsuit for all claims that were or could have been asserted in the Lawsuit or are otherwise included in the release under the Settlement. Although you cannot opt out of the Settlement, you can object to the Settlement as described above.

THE COURT’S FAIRNESS HEARING2 questions
16. When Will the Court Hold the Fairness Hearing?

On , December 17, 2026, at 9:00 a.m. Central Time, Judge Rowland will hold a hearing in her courtroom at Everett McKinley Dirksen U.S. Courthouse, 219 South Dearborn Street, Chicago, IL 60604.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, whether and in what amount to award Class Counsel with attorneys’ fees and reimbursement of expenses and the request for a service award. If there are objections, the Court will consider them. After the hearing, the Court will decide whether to approve the Settlement, and any award of attorneys’ fees, expenses or service award. Class Counsel does not know how long these decisions will take.

The time and date of this hearing may change, so please check Important Dates prior to the date of the hearing if you plan to attend. You should also contact Class Counsel if you intend to attend the hearing. Information about any dial-in or video conference will be posted on the website.

17. Do I Have to Attend or Can I Attend the Fairness Hearing?

You do not have to attend the hearing. Class Counsel will present the Settlement to the Court and answer any questions the Court may have. If you file a written objection, you do not have to attend the hearing in order for it to be considered by the Court.

You may come to the hearing at your own expense. You may also arrange for your own separate counsel to attend on your behalf (and at your own expense). You may also ask the Court for permission to speak at the hearing. To ensure that the Court will allow you to speak, you should send a “Notice of Intention to Appear at Fairness Hearing in “Paszkiet v. The Animal Doctor, LTD., et al, Case No. 1:24-cv-08403” to the Clerk of the Court at the addresses above, in advance of the hearing. Be sure to include your name, address, telephone number, and signature.

GETTING MORE INFORMATION1 question
18. How Do I Get More Information or Update My Address?

This Notice contains a summary of relevant court papers. Complete copies of public pleadings, Court rulings and other filings are available for review and copying at the Clerk’s office. The address is Everett McKinley Dirksen U.S. Courthouse, 219 South Dearborn Street, Chicago, IL 60604. Information is also available at www.animaldoctorplan.com, or by writing to the Settlement Administrator at the following address: Settlement Administrator, PO Box 414, Preston WA 98050 or telephone number: 866-418-0778.

For questions about the settlement, contact the Settlement Administrator. For questions about this the claims of the lawsuit contact Class Counsel.


If you want to make sure that the Settlement Administrator has your correct contact information, please call 866-418-0778 or Email info@animaldoctorplan.com.

PLEASE DO NOT CALL THE COURT, DEFENDANTS, OR DEFENDANTS’ COUNSEL WITH QUESTIONS REGARDING THIS NOTICE OR THE LAWSUIT.


Questions about this settlement?

Settlement Administrator Mailing Address

Paszkiet v. The Animal Doctor, LTDSettlement AdministratorPO Box 414Preston, WA 98050