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Data Breach Consumer No Proof Required

Holt Group Data Breach Settlement

Settlement Amount
$50 or up to $5,080
Claim Deadline
December 1, 2026
Total Fund
No shared fund
File on the official site → holtgroupdatasettlement.com

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Only people mailed a Holt notice letter qualify. That letter is the gate, and online filing needs the LoginID and PIN printed on it. The Holt Group Data Breach Settlement resolves claims arising from a targeted criminal third-party cyberattack on the network of B.D. Holt Co. d/b/a Holt Group — the San Antonio-based Caterpillar dealer that operates as HOLT CAT — in December 2024. Four things decide whether this page is worth your time. First, the class is a closed, letter-defined list. The Court defined it as individuals in the United States whose Private Information was potentially accessed in the incident of December 26–27, 2024 and who were sent a letter notifying them of it. Buying from Holt, renting from it or working for it does not put you in the class; being on the notice list does. The settlement website says that if you received notice, Holt Group’s records indicate you are a Class Member. If you are unsure, FAQ 6 tells you to ask the administrator free of charge at (833) 296-0885 — that call, not the claim form, is the real first step. Second, the $50 and the $5,080 are not the two ends of one scale. There are three cash options. Cash Payment A reimburses up to $5,000 in documented out-of-pocket losses and Cash Payment B pays up to $80 for lost time — four hours at $20 — and those two stack, which is the only way to reach $5,080. Cash Payment C is a flat $50 with no proof, and the court-approved Claim Form warns in capitals not to claim it if you are claiming either of the others. So the choice is $50 with nothing to document against documented losses plus lost time — and for a claimant with no receipts, that is $50 against $80. Note which cap covers what: $5,000 caps the documented-loss benefit only and $80 caps the lost-time benefit only. Neither caps the settlement. Third, two years of three-bureau credit monitoring is separate from all of that, with $1 million in fraud protection, open to every class member, and it pairs with any cash option — but it is its own checkbox on the Claim Form and you get nothing if you leave it blank. Fourth, the good news: there is no common fund, no overall cap and no pro rata reduction. The Notice describes amounts Holt Group pays per approved claim, and the $250,000 fee request and $5,000 service award are paid by Holt Group separately rather than out of class member benefits — so $50 here means $50. Claims close December 1, 2026; opting out and objecting close earlier, on November 16, 2026; and the Final Approval Hearing is set for December 16, 2026.

Do I Qualify?

You may be eligible if:

What you need depends entirely on which cash option you take — and the hardest requirement is not a receipt, it is the notice letter. The class gate, before any benefit. The Court defined the class to include only people who were sent a letter notifying them of the Data Incident. That is not a paperwork requirement you can satisfy with proof of your own; it is a question about Holt Group’s records. The settlement website states that if you received notice of the Data Incident, Holt Group’s records indicate you are a Class Member. There is no public lookup. FAQ 6 directs anyone unsure to contact the Settlement Administrator for free help at (833) 296-0885, toll free 24/7, or info@HoltGroupDataSettlement.com. To file online: the LoginID and PIN from that letter. The court-approved Claim Form states that the most efficient way to submit a claim is online using your unique LoginID and PIN at www.HoltGroupDataSettlement.com. But losing the letter does not end your claim. The printable Claim Form asks for the LoginID only “if known” — so the mail route works without it, as long as the form is postmarked by December 1, 2026. That is a meaningfully softer gate than most notice-ID settlements impose, and it is the single most useful thing to know on this page. For the $50 Alternate Cash payment: no documents at all. FAQ 7 and the Claim Form both state you do not have to provide any proof or explanation to claim the one-time $50.00 payment. Section V is a single checkbox — carrying the capitalized warning not to claim it if you are claiming from Section III or IV. For up to $5,000 in documented losses: real records, and an affidavit will not do. Section III asks you to itemize each expense and total it, with proof such as receipts showing how much you spent or lost. The Notice is explicit that your personal certifications, declarations or affidavits do not constitute reasonable documentation to make a valid claim, though you may include one to provide clarification, context or support for other submitted records. Losses must have occurred between December 26, 2024 and December 1, 2026, must have been caused by the Data Incident, and must not already have been reimbursed by a third party. Covered categories are a closed list: losses from identity theft or fraud; fees for credit reports, credit monitoring, or freezing and unfreezing credit; the cost of replacing IDs; and postage to contact banks by mail. If you have more expenses than rows, you may attach additional sheets, printing your name and signing the bottom of each. For up to $80 in lost time: an explanation, not receipts. Section IV has you select exactly one hour tier — 1 hour ($20), 2 hours ($40), 3 hours ($60) or 4 hours ($80) — and briefly describe how you spent the time on tasks related to the Data Incident. No documents are required, but the description is. For credit monitoring: just the checkbox. Section II needs nothing but a tick to enroll in two years of three-bureau monitoring with $1 million in fraud protection. The attestation is sworn. Section VII affirms, on penalty of perjury, that the information and supporting documentation are true and correct to the best of your knowledge, and acknowledges that the claim is subject to verification and that the administrator may request supplemental information before treating it as complete and valid.

File your claim through the official settlement website at holtgroupdatasettlement.com before December 1, 2026.

File on the official site → holtgroupdatasettlement.com

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What Happened?

B.D. Holt Co. does business as Holt Group and operates as HOLT CAT, a San Antonio-based Caterpillar heavy-equipment dealer serving Texas. The lawsuit alleges that during a targeted criminal third-party cyberattack on Holt Group’s network in December 2024, certain files containing Private Information may have been accessed. Per the court-approved Notice, those files may have contained personal information including some combination of names, Social Security numbers, driver’s license numbers and financial account information.

The settlement defines the incident window precisely: the Data Incident Holt Group experienced between December 26, 2024 and December 27, 2024. That two-day window, plus having been sent a notice letter, is the whole class definition.

Damon Quinn and Scott Moran sued on behalf of the class. The case is Damon Quinn and Scott Moran v. B.D. Holt Co., Case No. 2025CI06321, in the 37th Judicial District Court for Bexar County, Texas. Damon Quinn is the Class Representative. The Court appointed William B. Federman of Federman & Sherwood in Dallas and Jeff Ostrow of Kopelowitz Ostrow P.A. in Fort Lauderdale as Class Counsel; Holt Group is defended by Baker & Hostetler LLP.

Holt Group denies everything. The Notice records that the Defendant denies that it did anything wrong and denies all allegations, claims, wrongdoing and liability, and that the Court has not decided who is right. The parties settled to avoid the costs, risks, disruptions and uncertainties of continuing the case.

This is not a common fund settlement, and that is unusual enough to be worth stating plainly. The court-approved Notice describes benefits Holt Group has agreed to pay on approved claims. It sets out no aggregate settlement fund, no overall cap on payouts and no pro rata reduction, so the number of people who file does not change what any one claimant receives. The $250,000 in attorneys’ fees and costs Class Counsel will request, and the $5,000 Service Award for the Class Representative, are both paid by Holt Group separately from class member benefits.

The notice program and settlement website are live, run by Simpluris as Settlement Administrator. Claims are due December 1, 2026. Opt-outs and objections are due earlier, on November 16, 2026. The Final Approval Hearing is set for December 16, 2026 at 8:30 a.m. Central Time by video conference, and the website warns the date and time may change without further notice. No final approval order has been entered and no payment date has been announced.

One inconsistency on the official site, flagged so it does not trip you up: FAQ 11 states the Final Approval Hearing is on December 1, 2026, while FAQ 18, the homepage summary and the site’s Important Dates block all give December 16, 2026 at 8:30 a.m. Central. December 16 is the hearing; December 1 is the claim deadline.

Two documentation limits worth stating. First, neither the Notice, the Claim Form nor the settlement website discloses how many people are in the class, so there is no published figure for how many notice letters went out. Second, the Settlement Agreement is posted on the settlement website only as a scanned image with no searchable text layer. Everything on this page is drawn from the three documents that are readable — the court-approved Long Form Notice, the court-approved Claim Form, and the official settlement website and FAQs.

How to File Your Claim

  1. CHECK WHETHER A NOTICE LETTER WAS SENT TO YOU FIRST. Class membership turns on whether Holt Group’s records show a notice letter went to you about the December 26–27, 2024 Data Incident. If you are not sure, FAQ 6 says you can ask for free help any time: call the Settlement Administrator toll free, 24/7, at (833) 296-0885, or email info@HoltGroupDataSettlement.com. Do this before you spend time on the form
  2. FILE ONLINE at the official court-authorized settlement website, www.HoltGroupDataSettlement.com, run by Simpluris. The Claim Form states that the most efficient way to submit your claim is online using your unique LoginID and PIN. Online claims must be submitted by December 1, 2026 — the Notice gives no time of day or time zone for the online cutoff, so do not leave it to the last hours
  3. LOST THE LETTER? YOU CAN STILL FILE BY MAIL. The printable Claim Form asks for the LoginID only “if known,” so the paper route does not require it. Download the form from the settlement website, complete and sign it, attach any loss documentation, and mail it to Holt Group Data Incident Settlement, c/o Settlement Administrator, P.O. Box 25191, Santa Ana, CA 92799, postmarked no later than December 1, 2026. You can also ask the administrator to send you a Claim Form by phone, email or mail
  4. CHECK THE CREDIT MONITORING BOX SEPARATELY. Section II of the Claim Form is a standalone box for two years of three-bureau credit monitoring. It is not bundled into any cash option and it is not automatic — if you do not check it, you do not get it
  5. PICK YOUR CASH ROUTE CORRECTLY — THIS IS THE EASIEST PLACE TO LOSE MONEY. Section V of the Claim Form says in capitals: “DO NOT CLAIM THIS BENEFIT IF YOU ARE CLAIMING PAYMENTS FROM SECTION III OR IV.” The $50 Alternate Cash payment replaces both the documented-loss payment and the lost-time payment. Sections III and IV, by contrast, can be claimed together
  6. DOCUMENTED LOSSES NEED ACTUAL RECORDS. Section III asks you to itemize expenses and total them. The Notice and Claim Form both state that your personal certifications, declarations or affidavits do not constitute reasonable documentation on their own, though you may include one to add context to real records. Expenses already reimbursed by a third party cannot be claimed. If you have more expenses than rows, you may attach extra sheets, printing your name and signing the bottom of each
  7. LOST TIME IS ONE CHECKBOX PLUS AN EXPLANATION. Section IV asks you to select only one of 1 hour ($20), 2 hours ($40), 3 hours ($60) or 4 hours ($80), and to briefly describe how you spent the time
  8. CHOOSE HOW YOU WANT TO BE PAID — AND NOTE THAT ONLY ONLINE FILERS GET A CHOICE. Section VI of the Claim Form states that mailed claims are paid by paper check to the address on the form, while filing electronically on the settlement website gives you the option of a digital payment by PayPal, Venmo, Virtual Prepaid Card or Zelle. The form says a digital payment option is only available on the website
  9. WATCH THE EARLIER DEADLINE TOO. The claim deadline is December 1, 2026, but opting out and objecting both close two weeks sooner, on November 16, 2026. An opt-out must be postmarked or emailed to the administrator by then and must contain the case name, your full name, mailing address, telephone number, email address, your personal signature and words such as “Request for Exclusion” or “Opt Out.” An objection must be filed with the Clerk of the Court, 101 W Nueva Street, Suite 217, San Antonio, TX 78205, with copies mailed to the administrator, Class Counsel and Defendant’s counsel, and FAQ 16 lists ten separate items an objection must contain to be considered
  10. SIGN THE ATTESTATION. Section VII is a sworn statement, on penalty of perjury, that the information and supporting documentation are true and correct to the best of your knowledge, and acknowledges that the claim is subject to verification and that the administrator may ask for supplemental information
  11. QUESTIONS? The Settlement Administrator is reachable toll free 24/7 at (833) 296-0885, by email at info@HoltGroupDataSettlement.com, or by mail at P.O. Box 25191, Santa Ana, CA 92799. Court-appointed Class Counsel are William B. Federman of Federman & Sherwood in Dallas and Jeff Ostrow of Kopelowitz Ostrow P.A. in Fort Lauderdale
  12. FAQ 13 confirms you will not be charged for their services. Filing a claim is always free.
  13. Visit the official claim form: https://www.holtgroupdatasettlement.com/

How Much Will I Actually Get?

THE HEADLINE HIDES A FORK, AND THE $5,080 IS TWO SEPARATE CAPS ADDED TOGETHER. Take the structure in order, because the “$50 or up to $5,080” framing collapses three distinct benefits into one number. CREDIT MONITORING SITS OUTSIDE THE FORK ENTIRELY. Per FAQ 7 and the Claim Form, all Settlement Class Members are eligible to claim two years of three-bureau credit monitoring, which comes with $1 million in fraud protection and access to a fraud resolution agent if something suspicious happens. It is Section II of the Claim Form — its own checkbox — and nothing about it trades against any cash option. You can take the $50 and the credit monitoring. You can take documented losses and the credit monitoring. But you only get it if you check the box. CASH PAYMENT A — DOCUMENTED LOSSES, CAPPED AT $5,000. Reimbursement of up to $5,000.00 for actual, documented out-of-pocket losses caused by the Data Incident, for losses that occurred between December 26, 2024 and December 1, 2026. The Notice lists the covered categories: losses because of identity theft or fraud; fees for credit reports, credit monitoring, or freezing and unfreezing your credit; the cost to replace your IDs; and postage to contact banks by mail. Proof such as receipts is required, expenses already reimbursed by a third party are not claimable, and a personal certification, declaration or affidavit does not count as documentation by itself. CASH PAYMENT B — LOST TIME, CAPPED AT $80. Up to four hours at $20.00 per hour, for a maximum of $80.00, for time spent responding to the Data Incident — the Notice gives changing your passwords, investigating suspicious activity in your accounts and researching the Data Incident as examples. The Claim Form has you select one hour tier and briefly describe the time. No receipts are needed for this one, but an explanation is. A AND B STACK. THAT IS WHERE $5,080 COMES FROM. $5,000 of documented losses plus $80 of lost time is $5,080, and it is reachable only by a claimant who maxes out both halves. Neither cap applies to the settlement as a whole: $5,000 caps the documented-loss benefit only, and $80 caps the lost-time benefit only. For almost everyone the realistic documented-loss figure is whatever their receipts actually show, which is normally nothing, so the operative number on this page is $50 — or $80 for someone who can describe four hours of cleanup but has no out-of-pocket receipts. CASH PAYMENT C — $50, AND IT REPLACES BOTH A AND B, NOT JUST ONE. Instead of Cash Payment A or Cash Payment B, you may claim a one-time $50.00 cash payment with no proof or explanation of any kind. Section V of the court-approved Claim Form puts the trade-off in capitals: “DO NOT CLAIM THIS BENEFIT IF YOU ARE CLAIMING PAYMENTS FROM SECTION III OR IV.” So the real arithmetic is not “$50 versus $5,080” but “$50, with nothing to document, versus documented losses plus lost time.” A claimant with no receipts who can honestly describe four hours of cleanup is choosing between $50 and $80. THERE IS NO SETTLEMENT FUND, NO OVERALL CAP AND NO PRO RATA REDUCTION. This is genuinely good news and it is unusual. The court-approved Notice describes benefits Holt Group has agreed to pay on approved claims. It describes no aggregate settlement fund, no ceiling on total payouts and no mechanism for cutting payments if many people file. Your payment does not shrink because other class members claimed, and it does not grow because they did not. THE $250,000 IS A FEE REQUEST, NOT A FUND — AND IT DOES NOT COME OUT OF YOUR PAYMENT. Per FAQ 14, Class Counsel will ask the Court to approve $250,000.00 in attorneys’ fees and reimbursement of litigation costs, and a $5,000.00 Service Award for the Class Representative. The Notice states both amounts will be paid by Defendant. Nothing is deducted from class member benefits, which is why the $50 here is a true $50 rather than a ceiling net of fees. NOTHING IS PAID YET. FAQ 11 states that settlement payments will be distributed if the Court grants final approval and after any appeals are resolved. The Final Approval Hearing is set for December 16, 2026 at 8:30 a.m. Central Time by video conference, and the website warns the date and time may change without further notice. No payment date has been announced. ONE DATE ERROR ON THE OFFICIAL SITE, SO YOU ARE NOT CONFUSED BY IT. FAQ 11 says the Final Approval Hearing is on December 1, 2026, which is the claim deadline. FAQ 18, the homepage summary and the Important Dates block all say December 16, 2026 at 8:30 a.m. Central. December 16 is the hearing date; December 1 is the day your claim is due.

Last reviewed: October 8, 2026 | Information verified from court records and official settlement documents.

Frequently Asked Questions

I have dealt with HOLT CAT for years. Am I in this settlement?
Only if a notice letter about this incident was sent to you. This is the most important thing on the page, so it is worth being blunt: the Court defined the Settlement Class as “all individuals residing in the United States whose Private Information was potentially accessed or acquired in the Data Incident experienced by Defendant between December 26, 2024 and December 27, 2024 and who were sent a letter notifying them of the Data Incident.” Buying equipment, renting, financing, working for the company or living in its service area does not satisfy that last clause. The Long Form Notice says it even more directly: “You are a Settlement Class Member if you received notice of the Data Incident, including notice of this Settlement,” and the settlement website says that if you received notice, Holt Group’s records indicate you are a Class Member. Membership is decided by Holt Group’s files, and there is no public way to look yourself up. FAQ 6 tells you what to do instead: contact the Settlement Administrator for free at (833) 296-0885, toll free 24/7, or info@HoltGroupDataSettlement.com. For most people arriving here from a search, that call is the whole story.
Is this the Holt Group I am thinking of?
Check before you spend time on it. The Defendant in this case is B.D. Holt Co. doing business as Holt Group — the San Antonio-based Caterpillar heavy-equipment dealer that trades as HOLT CAT — sued in the 37th Judicial District Court for Bexar County, Texas, as Damon Quinn and Scott Moran v. B.D. Holt Co., Case No. 2025CI06321. Several unrelated American companies operate under the Holt Group or Holt name in other industries, and “Holt Group data breach” is an easy phrase to land on by accident. What identifies this settlement is a notice letter about a December 26–27, 2024 network incident at this company. If your letter was about a different company’s incident, this is not your settlement, and filing here will not help.
Can I claim the $50 and the documented losses?
No — and the trade-off is wider than most people assume. The $50 Alternate Cash payment, Cash Payment C, is available “instead of Cash Payment A or Cash Payment B,” and Section V of the court-approved Claim Form says so in capitals: “DO NOT CLAIM THIS BENEFIT IF YOU ARE CLAIMING PAYMENTS FROM SECTION III OR IV.” So taking the $50 gives up BOTH the documented-loss payment and the lost-time payment, not just one of them. Read it the other way round and the real decision becomes clear: $50 with nothing to document, versus documented losses plus lost time. If you have no receipts but can honestly describe four hours of cleanup, you are choosing between $50 and $80, not between $50 and $5,080.
Where does the $5,080 figure come from?
It is two separate caps added together, and reaching it requires maxing out both. Cash Payment A reimburses up to $5,000.00 in documented out-of-pocket losses. Cash Payment B pays up to four hours at $20.00 an hour, a maximum of $80.00, for time spent responding to the incident. Nothing in the Notice or the Claim Form makes you choose between those two — only Cash Payment C is exclusive of them — so $5,000 plus $80 is $5,080. Note carefully what each cap governs: the $5,000 caps the documented-loss benefit only and the $80 caps the lost-time benefit only. Neither is a cap on the settlement, and neither is an amount anyone receives by default. The documented-loss figure for almost every claimant is whatever their receipts actually show, which is usually nothing, which is exactly why the $50 no-proof option exists.
Can I take the $50 and still get the credit monitoring?
Yes. Credit monitoring sits entirely outside the cash fork. FAQ 7 states that all Settlement Class Members are eligible to submit a claim for two years of three-bureau credit monitoring services, which comes with $1 million in fraud protection and access to a fraud resolution agent if anything suspicious happens. On the Claim Form it is Section II, its own standalone checkbox, and the $50 Alternate Cash payment replaces only the two other cash options. So $50 plus two years of monitoring is a valid claim, as is documented losses plus lost time plus monitoring. The catch is the opposite of a trade-off: it is not automatic. If you do not check the Section II box, you do not get it.
I threw away the letter with the LoginID and PIN. Can I still file?
Yes, by mail — and this is better news than it is in most notice-gated settlements. The Claim Form directs online filers to use their unique LoginID and PIN at www.HoltGroupDataSettlement.com, so without them the website route is closed to you. But the printable Claim Form asks for the LoginID only “if known.” Download it from the settlement website, or ask the administrator to mail you one by calling (833) 296-0885 or emailing info@HoltGroupDataSettlement.com, complete and sign it, attach any loss documentation, and mail it to Holt Group Data Incident Settlement, c/o Settlement Administrator, P.O. Box 25191, Santa Ana, CA 92799, postmarked no later than December 1, 2026. One cost to weigh: Section VI says mailed claims are paid by paper check, while the digital payment options are available only to people who file on the website.
How will I be paid, and when?
How depends on which route you use. Section VI of the Claim Form states that if you submit by mail, an approved claim is paid by paper check to the address on the form. If you file electronically on the settlement website and do not also mail a form, you have the option of a digital payment by PayPal, Venmo, Virtual Prepaid Card or Zelle — the form says the digital payment option is only available on the website. As for when: no date has been announced. FAQ 11 states that settlement payments will be distributed if the Court grants final approval and after any appeals are resolved, and asks class members to be patient. The Final Approval Hearing is set for December 16, 2026 at 8:30 a.m. Central Time by video conference, and the website warns the date and time may change without further notice.
Does the $250,000 in attorneys’ fees reduce my payment?
No, and this is the structural feature that makes the headline numbers honest here. Per FAQ 14, Class Counsel will ask the Court to approve $250,000.00 as reasonable attorneys’ fees and reimbursement of litigation costs, and will also request a $5,000.00 Service Award for the Class Representative. The Notice states that both amounts will be paid by Defendant. Neither comes out of class member benefits. Nor is there a pot to divide: the court-approved Notice describes no aggregate settlement fund, no overall cap on payouts and no pro rata reduction, so the number of people who file changes nothing about any individual payment. The practical consequence is that $50 on this page means $50 — not $50 less a share of fees and administration costs, which is how most settlements of this size work.
What are the deadlines, and why do two different dates keep appearing?
There are three dates and they are easy to confuse. DECEMBER 1, 2026 is the claim deadline — online claims must be submitted by then and mailed Claim Forms must be postmarked by then. The Notice gives no time of day or time zone for the online cutoff, so do not leave it to the final hours. NOVEMBER 16, 2026 is both the opt-out deadline and the objection deadline, two weeks earlier than the claim deadline. An opt-out must be postmarked or emailed to the administrator by that date and must include the case name, your full name, mailing address, telephone number, email address, your personal signature and words such as “Request for Exclusion” or “Opt Out.” An objection has to be filed with the Clerk of the Court at 101 W Nueva Street, Suite 217, San Antonio, TX 78205, with copies mailed to the administrator, Class Counsel and Defendant’s counsel, and FAQ 16 lists ten separate items it must contain. DECEMBER 16, 2026 AT 8:30 A.M. CENTRAL is the Final Approval Hearing, by video conference. One note on the official site: FAQ 11 mistakenly gives the hearing date as December 1, 2026, while FAQ 18, the homepage and the Important Dates block all say December 16. December 16 is the hearing.
What happens if I do nothing?
You get nothing and you are still bound. FAQ 20 and the Notice are clear that unless you opt out you are automatically part of the Settlement, and if you do nothing you receive no benefits or payments while still giving up the right to sue, continue to sue or be part of another lawsuit against Holt Group or the Released Parties over the Released Claims. The releases are described in Section XI of the Settlement Agreement. Opting out, postmarked or emailed by November 16, 2026, is the only way to keep your own right to sue — and it means forfeiting all settlement benefits. Objecting is different: an objector stays in the class and can still file a claim and be paid if the Court approves the settlement.
Who is running this, and is the website legitimate?
The Settlement Administrator is Simpluris, and the court-authorized settlement website is www.HoltGroupDataSettlement.com, which states on its face that a Court authorized it and identifies the case as Damon Quinn and Scott Moran v. B.D. Holt Co., Case No. 2025CI06321, in the 37th Judicial District Court for Bexar County, Texas. The administrator can be reached toll free 24/7 at (833) 296-0885, by email at info@HoltGroupDataSettlement.com, or by mail at Holt Group Data Incident Settlement, c/o Settlement Administrator, P.O. Box 25191, Santa Ana, CA 92799. Court-appointed Class Counsel are William B. Federman of Federman & Sherwood in Dallas and Jeff Ostrow of Kopelowitz Ostrow P.A. in Fort Lauderdale; FAQ 13 confirms you will not be charged for their services. The settlement website also warns you not to contact the Court or Clerk of Court about the settlement. Filing a claim is always free.
How many people are in the class?
Not disclosed. Neither the court-approved Long Form Notice, the Claim Form nor the settlement website states the size of the Settlement Class, so there is no published figure for how many notice letters went out. That also means there is no way to estimate from public documents what Holt Group will pay in total — and because the settlement has no aggregate fund and no pro rata reduction, the class size would not change your own payment anyway. One related limit worth stating: the Settlement Agreement is posted on the settlement website only as a scanned image with no searchable text layer, so any figure circulating elsewhere that comes from the Agreement itself is not repeated here, because it could not be read at the source.

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