Notice of Proposed Settlement
of Collective Action Lawsuit

Defendant's records indicate that you worked on an hourly basis at a Novant Health affiliated facility during the relevant time period – September 19, 2021 to February 11, 2023 – and: (i) were subject to a time clock rounding policy; and (ii) worked at least one workweek of forty hours or more during the relevant time period ("Eligible Employees").

As a result, you have a right to know about this proposed Settlement, and about all of your options, before the Court decides whether to finally approve the Settlement. If and when the Court approves the Settlement, payments will be mailed to Eligible Employees who timely submit a valid Claim Form.

This Notice explains the Lawsuit, the proposed Settlement, your legal rights, and what benefits are available.

The Court overseeing this case is the United States District Court for the Middle District of North Carolina. This lawsuit is known as Corley, et al. v. Novant Health, Inc., Case No. 1:24-CV-772-WO-JEP (the "Lawsuit").

The person who filed the Lawsuit, Elizabeth Corley, is called the "Plaintiff" or the "Named Plaintiff." Novant Health is called the "Defendant."

Novant Health denies that any legal violation occurred and specifically asserts that you have been paid lawfully and properly for all your hours worked. The Court has not decided who is right or wrong and has not ruled on the merits of Plaintiff's claims or Defendant's defenses. Rather, instead of proceeding with the Lawsuit, the Parties reached a resolution of disputed claims, subject to Court approval.

This Lawsuit is about whether a timeclock rounding policy, which was in place up to February 11, 2023, caused a loss of overtime pay to certain employees. Defendant denies it did anything wrong, and asserts all employees were fully and properly paid.

In a collective action, one or more people called the "Named Plaintiff" sue on behalf of a group of people they assert have similar claims. These people together are called "Collective Members." If the collective is certified, one court resolves the issues for everyone in the lawsuit. If the collective is not certified, then the Lawsuit covers just the Named Plaintiff.

The Court did not decide in favor of Plaintiff or Defendant. Both sides believe they would have prevailed in the case, but there was no decision ruling in favor of either party. Instead, both sides agreed to a settlement. That way, they avoid the cost of a trial, the risk of losing, and the delay of litigating the case and of potential appeals, and the people affected are entitled to compensation.

You are eligible to become a member of the Collective Action if you worked for Defendant at any time during the relevant time period – September 19, 2021 to February 11, 2023 – and: (i) were subject to a timeclock rounding policy; and (ii) worked at least one workweek of forty hours or more during the relevant time period.

If you are still not sure whether you are included, you can ask for guidance. You can contact the Settlement Administrator as follows:

The total maximum amount to be paid by Defendant to settle the lawsuit is $750,000.00 and shall consist of the following: (i) alleged unpaid overtime and liquidated damages totaling a maximum of $403,730.00 of the Maximum Settlement Amount payable to participating Eligible Employees pursuant to the calculation set forth below in paragraph 8; (ii) a Service Award in the maximum amount of $5,000.00 payable to Named Plaintiff Elizabeth Corley; (iii) attorneys' fees and litigation costs in the maximum amount of $265,000.00 payable to Anderson Alexander, PLLC; and (iv) claims administration costs in the amount of $76,270.00.

The payments made by Defendant under the Settlement Agreement will cover payments to Eligible Employees who timely submit a valid Claim Form. If you have not already joined the Lawsuit, to receive any settlement payment, you must timely submit a valid Claim Form. However, if you previously opted-in to the Lawsuit, you need not submit a Claim Form and will receive your settlement payment following final approval of the Settlement.

Your payment will be determined based on a formula that has been preliminarily approved by the Court. You may be entitled to your proportional share of the Settlement—which will be calculated based on the number of work weeks you were employed in a non-exempt position during the relevant time period – September 19, 2021, through February 11, 2023.

If you timely submit a valid Claim Form, your estimated settlement payment will be $[____________].

Neither Collective Counsel nor Defendant or its counsel makes any representations concerning tax consequences of this Settlement or participation in it, and you are advised to seek your own personal tax advice prior to acting in response to this Notice.

To get your payment, you must timely return a valid Claim Form to the Settlement Claims Administrator postmarked or electronically submitted no later than July 10, 2026. You may return your Claim Form electronically or via U.S. mail to:

If you timely return a valid Claim Form to the Settlement Administrator that is electronically submitted or postmarked by the deadline, you will be sent a Settlement Check if and when the Court finally approves the settlement and after any appeals have been exhausted.

The deadline for submitting a valid Claim Form is July 10, 2026. Following this deadline, there are additional court proceedings required for final approval of the Settlement. Please be patient and do not contact the Court with questions regarding the Settlement or the timing of the settlement payment. If you have questions regarding these issues, please contact the Settlement Administrator at the contact information listed in Paragraph 14.

You will have exactly sixty (60) days from mailing to cash the check which represents your payment in this matter. If you fail to cash your check within that time period, you have an additional period of 180 days following the close of the check cashing period to request a new check from the Settlement Administrator. Please cash your check promptly as if you fail to cash your check within these timeframes, you will not receive any additional payment.

If you timely submit a valid Claim Form, you will become a Collective Member. This means that you cannot sue, continue to sue, or be part of any other lawsuit against Defendant about the wage and hour issues in this case. It also means that all of the Court's orders will apply to you and legally bind you.

By signing, dating, and timely returning this Claim Form, you agree to be bound by the Settlement Agreement negotiated by Collective Counsel, you consent to become a party plaintiff to this action under the federal Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. ("FLSA"), and agree, on behalf of yourself, and your current, former, and future heirs, spouses, executors, administrators, agents, and attorneys, to the following release:

The Court has preliminary approved the law firms of Anderson Alexander, PLLC and Higgins Benjamin, LLC ("Collective Counsel") to represent the Named Plaintiff and all Collective Members who timely submit a valid Claim Form. You do not need to retain your own attorney in order to participate as a Collective Member.

Collective Counsel will ask the Court to approve payment of up to approximately thirty-five percent of the total Maximum Settlement Amount for attorneys' fees and costs in the amount of Two Hundred Sixty-Five Thousand Dollars and Zero Cents ($265,000.00). These fees and costs would compensate Collective Counsel for investigating the facts, litigating the case, and negotiating the Settlement. The cost of the Settlement Administrator will also come from the Settlement Amount in an amount not to exceed $76,270. Collective Counsel will also ask the Court to approve a Service Award not to exceed Five Thousand Dollars and No/100 Cents ($5,000.00) to the Named Plaintiff who initiated the Lawsuit in recognition of the risks she took, her service to the Collective, and the recovery obtained for the Collective.

This notice summarizes the proposed Settlement. More details are in the Settlement Agreement. If you have other questions about the Settlement, you can contact the Settlement Administrator at the address and/or telephone number listed below.

You can also get a copy of the Settlement Agreement by sending a request, in writing, to:

If you change your address or reside at an address other than the one at which this notice was mailed to you, please promptly inform the Settlement Administrator of your new address to ensure processing of your claim and mailing of your check to the correct address. It is your responsibility to keep a current address on file with the Settlement Administrator.