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SunLife Class Notice Packet

A federal court has preliminarily approved a class action settlement regarding dependent child life insurance claims against Union Security Insurance Company and Sun Life Assurance Company. Class members may receive benefits based on their claims, including payments for previously denied claims and options for converting policies, while also releasing any future claims against the defendants. Members have the right to object to the settlement or opt-out if they have pending lawsuits related to the claims addressed in this settlement.

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0% found this document useful (0 votes)
63 views16 pages

SunLife Class Notice Packet

A federal court has preliminarily approved a class action settlement regarding dependent child life insurance claims against Union Security Insurance Company and Sun Life Assurance Company. Class members may receive benefits based on their claims, including payments for previously denied claims and options for converting policies, while also releasing any future claims against the defendants. Members have the right to object to the settlement or opt-out if they have pending lawsuits related to the claims addressed in this settlement.

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antoniopol
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

NOTICE OF CLASS ACTION SETTLEMENT

in
SUN LIFE/UNION SECURITY DEPENDENT CHILD LIFE INSURANCE
LITIGATION
Lewis-Abdulhaadi v. Union Security Ins. Co., Case No. 2:21-cv-03805-WB (E.D. Pa.)

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.
The United States District Court for the Eastern District of Pennsylvania preliminarily
approved a settlement of the above-entitled lawsuit and authorized this notice.

You are receiving this notice either because Union Security Insurance Company (“USIC”)
or Sun Life Assurance Company of Canada (“Sun Life”) identified you as a Class member
or your current or former employer identified you as a potential Class member. (Assurant
Employee Benefits was the brand name for group life insurance policies underwritten by
USIC).

This notice summarizes the Settlement and informs you of your rights under the Settlement.
The complete Settlement Agreements, and other information about this lawsuit, are
available at ERISAsettlementsunlife.com or by contacting Class Counsel listed below.

SUMMARY OF YOUR LEGAL RIGHTS & OPTIONS


Your benefits and what you must do to obtain them depend on what
category you are in (as fully described in Question No. 4 below):
If you previously submitted a claim for dependent child life insurance
benefits that was denied between August 25, 2015, and March 14, 2025
which was denied based on the child’s age, you do not need to take any
OPTION #1
action to receive payment (unless you need to update your contact or
(FOR ALL
provide beneficiary information - see section 5, Group #1).
CLASS
MEMBERS): If your child passed away between August 25, 2015, and March 14, 2025
Obtain a but you did not previously submit a claim for dependent child life insurance
payment or benefits, you must submit a Claim as detailed below to receive benefits.
benefits under If you paid premiums for a child who was above the allowed age for
the Settlement dependent child life insurance (generally above 19 if not a full-time student
or above 25 and not disabled but may vary depending on the terms of the
group policy) and your child is still alive, you can convert the life insurance
to an individual policy for each such child. You must submit a Notice of
Interest in Conversion Coverage as detailed below to receive this
benefit.

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Telephone: (888) 348-1388
OPTION #2 If you are not satisfied with the terms of the proposed Settlement, then you
(FOR ALL or your attorney may inform the Court by sending a letter or written
CLASS statement postmarked by March 3, 2025, at the address listed below. If you
MEMBERS): object, you can still receive benefits under the Settlement if the Court
Object enters final approval of the settlement.
If you have filed a lawsuit concerning the denial of dependent life insurance
OPTION #3
for a child who passed away between August 25, 2015 and March 14, 2025,
(ONLY IF YOU
and that lawsuit is currently pending, you may opt-out of the Settlement
FILED A
and exclude yourself from the Class by sending a letter or written statement
SEPARATE
by March 3, 2025, at the address listed below. If you have not filed such a
LAWSUIT):
lawsuit you may not opt-out of the Settlement. If you opt-out, you will not
Opt-out
receive a payment or other benefits under the Settlement.

BASIC INFORMATION

3. What Is This Case About?


This is a class action on behalf of certain participants in employee benefit plans covered by the
Employee Retirement Income Security Act (“ERISA”) challenging practices regarding dependent
child life insurance. The Complaint alleges that Plaintiff and the Class paid and that USIC and Sun
Life received premiums collected by the employers of the plan participant for dependent child life
insurance coverage under a group life insurance policy for which the dependent children were not
eligible. Plaintiff filed a claim for benefits following the death of her son that was denied because
her son was older than the maximum allowable age for eligibility as a dependent child under the
group policy issued to her employer. Plaintiff has brought claims against USIC and Sun Life under
ERISA on behalf of a Class of similarly situated individuals. A detailed description of the claims
is contained in the First Amended Complaint, which is available on the following website:
ERISAsettlementsunlife.com. Defendants deny the allegations of the Complaint and contend that
they complied with the law and the provisions of the group life insurance policy.

2. 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. A class representative, such as Plaintiff here, files a lawsuit asserting claims on behalf
of the entire class. The “Class Representative” in this case is Antoinette Lewis, who had two
children enrolled in child dependent life insurance with USIC and then Sun Life through her
employer’s group plan.
3. Who is a Member of the Class?

The Court defined the “Class” as follows:


All participants in an ERISA-covered plan that provided or offered dependent child
life insurance that is or was insured by Sun Life Assurance Company of Canada or
Union Security Insurance Company at any time from and including August 25,
2015 until March 14, 2025, and for which a participant paid premiums
(or premiums were paid) for at least one child in such dependent child life insurance
coverage and either (i) had no enrolled children who met the definition of dependent

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child under the policy while such premiums were paid for coverage (“Class
Members Without Dependent Children”) or (ii) had a claim for dependent child life
insurance denied because the child’s age was beyond the oldest allowable age for a
dependent child under the applicable policy or based on the child’s age and because
the child was not a full-time student (“Class Member(s) With Denied Claim(s)”);
and the beneficiaries of such persons.
Excluded from the Class are persons who are either (1) any fiduciaries of the Plans
with decision-making or administrative authority related to the establishment,
administration, funding or interpretation of the Plan, or (2) persons not eligible for
benefits under Section IV of the Settlement Agreement [i.e., described in No. 5 of
this Notice].
Additionally a person does not meet the requirements of Section (ii) of the Class
Definition unless (a) Defendants identify that person as a Class Member With
Denied Claim or (b) the claim for dependent child life insurance was denied solely
because the child’s age was beyond the oldest allowable age for a dependent child
under the applicable policy or a claim denied solely based on the child’s age and
because the child was not a full-time student.
If you meet the definition of the Class and are not excluded as set forth above, you are a Class
Member. Merely receiving this Notice does not mean that you are a Class Member. You must
meet the Class definition to qualify.

4. Why Did I Get This Notice?

You received this Notice because the Court ordered that Notice be provided to the Class. You were
identified as a potential member of the Class either from the records of USIC or Sun Life or
because a current or former group life insurance policyholder has identified you as a potential
member of the Class. 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. Receipt of this Notice does not mean that you are a
Class member, only that you may be a Class member.
THE PROPOSED SETTLEMENT
5. What Are the Benefits Provided By the Settlement Agreement?

The benefits to which Class Members are entitled depend on the following categories:

Group 1: Class Members Who Previously Filed Claims That Were Denied.
Eligible Class Members You are a Class Member With a Denied Claim–i.e., you paid
premiums (or premiums were paid by your employer) for at least
one child in such dependent child life insurance coverage, and had
a claim for dependent child life insurance benefits denied during the
Class Period EITHER (A) because the child’s age was beyond the
oldest allowable age for non-disabled dependent children under the
applicable group life insurance policy OR (B) based on the child’s
age and because the child was not a full-time student.
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Telephone: (888) 348-1388
Benefits Provided For Group (A) Above: Sun Life will pay 100% of the dependent
child life insurance benefit amounts elected under the applicable
policy that were previously denied. Accidental death benefits are
not recoverable.
For Group (B) Above: Sun Life will pay 50% of the dependent
child life insurance benefit amounts under the applicable policy that
were previously denied. Accidental death benefits are not
recoverable.
What Needs to be Done Nothing. You will receive a check. Please update the Settlement
to Obtain Benefits Administrator about any change to your contact information. If the
participant is now deceased and you are the beneficiary, you must
inform the Settlement Administrator and provide the beneficiary
designation (usually obtained from the employer) by no later than
March 27, 2025.

Group 2: Class Members Whose Child Died or Dies BUT DID NOT Previously File a Claim.
Eligible Class Members You are a Class Member Without Eligible Dependent Children
whose child passed or passes away between August 25, 2015 and
March 14, 2035, BUT no claim for dependent child life
insurance benefits has been previously filed.
Benefits Provided Sun Life will pay 100% of the dependent child benefits under the
applicable group policy without considering whether the decedent
was older than the maximum allowable age so long as the child died
before age 40 and you had dependent child life insurance coverage
issued by SunLife or USIC for at least 6 consecutive months before
the child’s death.
What Needs to be Done If the Child You should submit to the Settlement
to Obtain Benefits Died Before Administrator a Notice of Potential Claim on
March 14, 2025 the form attached hereto. You must file a claim
for benefits by 90 days after the Final Approval
Order becomes Non-Appealable (which date
will be at least 30 days after the Final Approval
Hearing set for March 14, 2025).
If the Child You must submit the claim in the manner
Dies AFTER outlined in the Summary Plan Description or
March 14, 2025 the applicable group insurance policy. If you do
not have those documents, you can request them
in writing from the Plan Administrator (usually
your employer).

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Telephone: (888) 348-1388
Group 3: Class Members For Which Premiums Were Paid for a Child That Did Not Qualify
as a Dependent Child under the Policy.
Eligible Class Members You are a Class Member Without Eligible Dependent Children for
whom premiums were paid for a child who did not satisfy the
definition of dependent child under the applicable policy (generally
the child was 19 or older if not a full-time student and not disabled
or over 26 if not disabled but may vary depending on the terms of
the group policy).

This does not apply to children who die before March 14, 2025.
Benefits Provided Sun Life will allow you the option to purchase an individual policy
of conversion life insurance for children who did not satisfy the
definition of dependent child under the applicable policy while
premiums were being paid.

The conversion policy will be issued by Sun Life in a policy form


approved by your state. Premiums will be based on the age of the
child at the time of the application as approved by applicable state
insurance authority. The maximum amount of the life insurance
shall be the lesser of $10,000 or the amount for which the child was
insured when the child ceased be eligible as a dependent child under
the applicable group policy.
What Needs to be Done Step #1: You must submit a Notice of Interest in Conversion
to Obtain Benefits Coverage no later than 120 days after March 14, 2025, on the
attached form.

Step #2: After Final Approval, Sun Life will send you a formal
conversion application if you have submitted a Notice of Interest in
Conversion Coverage. You need to submit the completed
application and premium 30 days after you receive the application.
If the conversion application is approved and the premium is paid,
coverage for each applicant will be retroactively effective on the
Preliminary Approval Date, and except as modified by the
Settlement, will be subject to all terms and conditions of the
conversion policy.

Note: If you do not timely complete both steps, your child will
not be entitled to the conversion coverage. Class Members who
elect and are approved for conversion coverage are not eligible
for any benefits under Group #2 above.

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

In exchange for the benefits in the Settlement, the Class will release (i.e., give up) any and all
claims against USIC and Sun Life as outlined in the Amended Complaint and those that are based
on the same facts – namely, the collection of premiums for dependent child life insurance where
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Telephone: (888) 348-1388
the child exceeded the age limits under the applicable policy, the denial of the payment of claims
for such children and the failure to provide notice about conversion coverage or other disclosures.
The Settlement also provides for a release of the fiduciaries of the Plans through which this child
dependent life insurance was provided so long as the fiduciaries do not assert any claims or
challenges against the Class Members. Release of claims against a Plan Administrator is
conditioned upon the Plan Administrator issuing the Class Notice.

The full terms of the Settlement, including the releases, are available at
ERISAsettlementsunlife.com. If the Settlement is finally approved, the Court will enter an order
dismissing with prejudice all claims against Defendants and preventing any Class members from
suing these Defendants and the fiduciaries of the Plans in the future on the released claims.

If and only if you currently have a pending lawsuit concerning the denial of dependent child life
insurance for which the child passed away between August 25, 2015 and March 14, 2025, you can
timely exclude yourself from the Settlement by timely submitting a written Opt-Out Request to
the Settlement Administrator, as further detailed below, and retain your rights to continue your
pending lawsuit against USIC and/or Sun Life for the above claims. Otherwise, you will only be
entitled to the benefits of this Settlement.

7. Can the Settlement be Terminated?

The Settlement may be terminated under several circumstances, including if the Court does not
approve the Settlement. If the Settlement is terminated, the claims against Defendants 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 (i.e., objections) have been resolved
(or the time to file all appeals has expired). The earliest that the Settlement will be final is 30 days
after the Final Approval Hearing, but it may be later than that. Your patience is appreciated.

8. Why Did the Settling Parties Reach This Settlement?

In deciding to settle the lawsuit, Class Counsel reviewed thousands of pages of documents,
conducted more than seven depositions, and retained an expert. Class Counsel also considered the
strength of the claims and defenses and the arguments by Defendants, the expense, length and
likely delay of further litigation, and the risks arising from the existence of unresolved questions
of law and fact. USIC and Sun Life disputed all of the claims in the lawsuit and asserted various
legal defenses. If the parties had not reached a settlement and USIC and Sun Life had prevailed on
certain of their defenses, then the Class could have recovered nothing.

Following briefing on Plaintiff’s Motion for Class Certification and significant discovery, the
parties agreed to participate in mediation. A settlement with USIC and Sun Life was reached only
after multiple mediation sessions with a mediator experienced in ERISA cases. Plaintiff, Class
Counsel and Defendants determined that given the uncertainty and risks inherent in litigation, it
was best to settle the case on the terms set forth in the Settlement Agreement.

This is only a summary of the Settlement. For its complete terms, interested persons are
encouraged to view information about the case and the Settlement at ERISAsettlementsunlife.com,
or review the Settlement Agreement on file with the Clerk of the Court. If you have questions, you
may contact Class Counsel (contact information provided below).
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Telephone: (888) 348-1388
THE LAWYERS REPRESENTING YOU

9. Do I Have a Lawyer in this case?

The Court has appointed the following law firms to serve as attorneys for the Class:

Co-Lead Class Counsel: Co-Lead Class Counsel: Co-Lead Class Counsel:


R. Joseph Barton Jonathan Feigenbaum Adam Harrison Garner
BARTON & DOWNES LLP 184 High Street, Suite 503 THE GARNER FIRM, LTD.
(n/k/a The Barton Firm LLP) Boston, MA 02110 One Penn Center
1633 Connecticut Ave., Ste. 200 Telephone: (617) 357-9700 1617 John F. Kennedy Blvd.,
Washington, D.C. 20009 [email protected] Suite 550
Telephone: (202) 734-7046 Philadelphia, PA 19103
[email protected] Telephone: (215) 645-5955
[email protected]

13. How Will the Lawyers be Paid?

Class Counsel have worked on this case for over three years and have not yet been paid for their
time. In prosecuting this case on behalf of the Class, Class Counsel investigated the facts,
interviewed witnesses, attended court hearings, reviewed documents produced in discovery, took
depositions, prepared legal pleadings, and participated in multiple mediation sessions and
subsequent negotiations. To date, Class Counsel have incurred over 2,099 hours in this case and
have advanced over $45,251 in out-of-pocket expenses on behalf of the Class, including for
depositions and expert witnesses. Under the Settlement, USIC and Sun Life will pay $1 million
into a Fees & Expense Fund to resolve any claims for attorneys’ fees and expenses. Class Counsel
will apply to the Court for an award of fees and expenses from the Fees & Expense Fund, not to
exceed $1 million. Class Counsel may also apply to the Court for a service award to the Class
Representative in an amount not to exceed $5,000, which, if approved by the Court will be paid
from the Fees & Expense Fund. The Motion for Attorneys’ Fees, Litigation Expenses, and Service
Award will be available for review on the website maintained by the Settlement Administrator or
via PACER. Class Counsel will file a Motion for Attorneys’ Fees, Litigation Expenses, and Class
Representative’s Service Award no later than February 24, 2025.

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 service award must state that objection in
writing by the deadline for objections and may appear at the Court’s fairness hearing. Whether or
not you submit a written objection, you are not required to appear at the hearing.

THE COURT’S FINAL APPROVAL HEARING

14. When Will the Court Hold the Final Approval Hearing?

On March 14, 2025, at 2:00 p.m. Eastern Time, Judge Beetlestone will hold a hearing at the United
States District Courthouse in Philadelphia, Pennsylvania:

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Telephone: (888) 348-1388
United States Courthouse
601 Market Street
Courtroom 10-A
Philadelphia, PA 19106
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 Class Representative with 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
award attorneys’ fees and expenses and/or a service award. We do not know how long the Court
will need in order to make these decisions.
The time and date of this hearing may change, so please contact Class Counsel or check
ERISAsettlementsunlife.com prior to the date of the hearing if you plan to attend.

15. Do I Have to Attend or Can I Attend the Final Approval 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 are not required to
attend the hearing in order for your objection 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 Lewis-Abdulhaadi v. Union
Security Ins. Co., Case No. 2:21-cv-03805-WB (E.D. Pa.)” to Class Counsel and/or the
Settlement Administrator at the addresses listed in this Notice no later than 14 days prior to the
final fairness hearing date. Be sure to include your name, address, telephone number, and
signature.
HOW TO PROCEED

16. 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 the
Settlement or some part of it, including the motion for attorneys’ fees and expenses or the service
award to the Class Representative. To object, you must send a letter or other written statement
with your objection.
Any written objections must be sent to Class Counsel and/or the Settlement Administrator
at the addresses listed in this Notice and must be postmarked no later than March 3, 2025.

Be sure to refer to “Lewis-Abdulhaadi v. Union Security Ins. Co., Case No. 2:21-cv-03805-WB
(E.D. Pa.).” Include your name, address, telephone number, signature, and a full explanation of all
the reasons you object to the Settlement. The Settlement Administrator or Class Counsel will
submit your objection to the Court.

If you do not object to the Settlement, or the request for attorneys’ fees and costs, then you do not
need to file any papers with the Court.
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Telephone: (888) 348-1388
17. How Do I Update My Information?

If you need to update your mailing address, other contact information or advise that the participant
who is a Class member is deceased, you should complete the attached contact form. If you need to
provide any other updates, you should also contact the Settlement Administrator at the address or
telephone number provided below.

18. Can I Opt-Out of the Class?

The Court has certified this case as a mandatory class action, but has only allowed a choice to opt
out for persons who filed a lawsuit challenging the denial of dependent child life insurance for
which the child passed away between August 25, 2015 and March 14, 2025. If you filed such a
lawsuit and it is currently pending, you may opt-out of the Settlement and exclude yourself from
the Class by sending a letter or written statement by March 3, 2025, at the address listed below.
If you have not filed such a lawsuit you may not opt-out of the Settlement.

Opting out is different from objecting. Objecting is telling the Court you think there is an issue
with the Settlement, and you are asking the Court not to approve it. You can object only if you
remain a Class Member (which means you do not opt-out of the settlement). Opting out is telling
the Court you do not want to be a Class Member. If you exclude yourself, you have no basis to
object because the case no longer affects you. If you opt-out, you will not receive a payment or
other benefits under the Settlement.
GETTING MORE INFORMATION
19. How Do I Get More Information?
There are several types of information that you may want about the settlement:
For questions about settlement procedures, forms & administration of the Settlement, or
the information about you, contact the Settlement Administrator. You may contact the
Settlement Administrator at the following address, email or toll-free telephone number:

Sun Life ERISA Settlement Administrator


c/o Class Experts Group, LLC
P.O. Box 995
Mequon, WI 53092
Email: [email protected]
Toll-Free telephone number: (888) 348-1388
For questions about the lawsuit or the Settlement overall, contact Class Counsel.
Do not contact USIC or Sun Life with questions about the Settlement as they will not be
able to answer questions about the Settlement. Contact Your Plan Administrator or
Sun Life about questions related to Conversion Coverage.

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Telephone: (888) 348-1388
20. How Do I Receive Any Updates and/or Update My Address?
The best way to receive updates is to check the information on ERISAsettlementsunlife.com before
you contact Class Counsel. If your question is not answered on the website, contact either the
Settlement Administrator or Class Counsel at the addresses, email addresses, or telephone numbers
listed above.
Please remember that there are many Class Members so it will take a little while to process
this Settlement. Your patience is appreciated.
If you need to provide updated address information, please complete the form on
ERISAsettlementsunlife.com and email it to the Settlement Administrator at the following email
address: [email protected] or the mailing address above.

PLEASE DO NOT CALL THE COURT WITH QUESTIONS REGARDING THIS NOTICE OR THE
SETTLEMENT.

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Telephone: (888) 348-1388
NOTICE OF POTENTIAL CLAIM (GROUP 2)
SUN LIFE /USIC DEPENDENT CHILD LIFE INSURANCE LITIGATION
Lewis-Abdulhaadi v. Union Security Ins. Co., Case No. 2:21-cv-03805-WB (E.D. Pa.).
If you are a Class Member whose child passed away between August 25, 2015 and March 14, 2025,
but no claim for benefits has yet been submitted (i.e., you fall within Group 2 of the Notice of
Class Action Settlement), 1 you should complete the information below and submit it to the
Settlement Administrator at the address listed below.
If you submit this form before the Final Approval Hearing scheduled for March 14, 2025, Sun Life
will send you the claim forms necessary to file a claim after final approval of the settlement by the
Court. You will have 90 days after the date of the final approval of the settlement becomes Non-
Appealable (which will be at least 30 days after the Final Approval Hearing) to submit the claim forms.
Name:
Address:
Email:
Telephone Number:
Name of Policyholder/
Employer (if known):
Policy Number (if known):
Date Premiums for
Dependent Child Life
Coverage with USIC/Sun
Life Began (if known):
Date Premiums for
Dependent Child Life
Coverage with USIC/Sun
Life Ended (if known):
Name of Deceased Child:
Date of Birth:
Date of Death:
I hereby verify that the foregoing information is true and accurate to the best of my knowledge and
belief.

______________________ _________
Signature Date
Return this Form to the Settlement Administrator at:
Sun Life ERISA Settlement Administrator
c/o Class Experts Group, LLC
P.O. Box 995
Mequon, WI 53092

1
If you are a Class Member and your child passes away after March 14, 2025, you should submit a claim in the manner
outlined the Summary Plan Description for your plan or the applicable group insurance policy/certificate of insurance.
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NOTICE OF INTEREST IN CONVERSION (GROUP 3)
SUN LIFE USIC/ DEPENDENT CHILD LIFE INSURANCE LITIGATION
Lewis-Abdulhaadi v. Union Security Ins. Co., Case No. 2:21-cv-03805-WB (E.D. Pa.).
If you are a “Class Member Without Eligible Dependent Children” for whom premiums were paid
for a child who did not satisfy the definition of dependent child under the applicable policy and
want to obtain a benefit described for Group 4 of the Notice of Class Action Settlement, you must
complete and submit this form.
Amount of Coverage Available: The maximum amount of the life insurance shall be the lesser
of $10,000 or the amount for which the child was insured when the child ceased be eligible as a
dependent child under the applicable group policy.
Premium Information: The premium for this individual life insurance is based on the dependent’s
age closest to the effective date of the policy. The Addendum to this form provides the rates and
example to help calculate the annual premium.
Applying for conversion coverage involves a two-step process:
Step 1: Complete the information below and mail it to the Settlement Administrator
by July 12, 2025.
Step 2: After final approval of the settlement, Sun Life will send you a formal application and
other documents to complete. Then you will have 30 days from receipt of the application to submit
the following to Sun Life (1) completed application; (2) completed W-9 form; (3) a check in the
premium amount (Bank Authorization form and voided check if you would like automatic
withdrawals); (4) a copy of government issued ID. Acceptable forms include driver’s license,
passport or a state issued ID card.
Complete Step 1 by completing this information
Name:
Address:
Email:
Name of Policyholder (if known,
usually employer):
Policy Number (if known):
Date Premiums for Dependent Child
Life Coverage with USIC/Sun Life
Began (if known):
Date Premiums for Dependent Child
Life Coverage with USIC/Sun Life
Ended (if known):
Dependent Children Name of Child Date of Birth

1
Lewis-Abdulhaadi v. Union Security Ins. Co., Website: ERISAsettlementsunlife.com
Case No. 2:21-cv-03805-WB (E.D. Pa.) Email: [email protected]
Telephone: (888) 348-1388
I hereby verify that the foregoing information is true and accurate to the best of my knowledge and
belief.

______________________ _________
Signature Date

Return this Form to the Settlement Administrator at:

Sun Life ERISA Settlement Administrator


c/o Class Experts Group, LLC
P.O. Box 995
Mequon, WI 53092

2
Lewis-Abdulhaadi v. Union Security Ins. Co., Website: ERISAsettlementsunlife.com
Case No. 2:21-cv-03805-WB (E.D. Pa.) Email: [email protected]
Telephone: (888) 348-1388
ADDENDUM
Example to calculate your annual premium for 30 year old
$10,000 (amount of coverage) divide by 1,000 = 10
10 * 12.58 (rate from table below) + $125 (annual fee) = $250.80 (annual premium)
Calculate your annual premium
Include the applicable numbers for your dependent in the calculation formula below and repeat for
each dependent
$_________ (amount of coverage) divide by 1,000 = ___* ___(rate) + $125 (annual fee) = $____ (annual premium)

Rate Table
Issue Age Rate Issue Age Rate Issue Age Rate
(per $1,000) (per $1,000) (per $1,000)
19 9.21 30 12.58 41 19.97
20 9.44 31 13.05 42 20.90
21 9.67 32 13.52 43 21.72
22 9.83 33 14.11 44 22.89
23 10.14 34 14.69 45 23.94
24 10.37 35 15.39 46 25.68
25 10.72 36 15.98 47 26.88
26 11.07 37 16.68 48 28.20
27 11.42 38 17.51 49 29.52
28 11.77 39 18.21 50 30.96
29 12.12 40 19.03 51 32.52

Rates for other ages will be provided along with your application.

3
Lewis-Abdulhaadi v. Union Security Ins. Co., Website: ERISAsettlementsunlife.com
Case No. 2:21-cv-03805-WB (E.D. Pa.) Email: [email protected]
Telephone: (888) 348-1388
CLASS MEMBER CONTACT INFORMATION FORM
SUN LIFE/USIC DEPENDENT CHILD LIFE INSURANCE LITIGATION
Lewis-Abdulhaadi v. Union Security Ins. Co., et al. No. 2:21-cv-03805 (E.D. Pa.)

Class Member Information

1. Name:

2. Address:

3. Non-Work Email:

4. Telephone: Home ( ) -

Cell ( ) -

5. Check one of the following:

a. [_] I am the participant (i.e., employee)

b. [_] The participant has passed away and I am the designated beneficiary. If so,

check one of the following:

[_] I am attaching the beneficiary form.

[_] I will send the beneficiary form by no later than March 27, 2025.

c. [__] The participant passed away and there is no designated beneficiary. My

relationship to the participant is: _______________________________________

6. Name of Policyholder (i.e. Employer):

Thank you for completing this form. Please mail or email or fax this form to:

Email: [email protected]
Fax: (888) 348-1389
Mailing Address:
Sun Life ERISA Settlement Administrator
c/o Class Experts Group, LLC
P.O. Box 995
Mequon, WI 53092

1
Lewis-Abdulhaadi v. Union Security Ins. Co., Website: ERISAsettlementsunlife.com
Case No. 2:21-cv-03805-WB (E.D. Pa.) Email: [email protected]
Telephone: (888) 348-1388

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