Question 1

Why was this Notice issued?

Accepted Answer

A Court has authorized this Notice because you have a right to know about the
proposed Settlement in the Action and your options before the Court decides
whether to give final approval of the Settlement. This Notice explains the
Action, the Settlement, and your legal rights and options.

A U.S. District Court Judge for the Northern District of California is presiding
over the Action. The Action is styled Julie Grundstrom, et al., v. Wilcac Life
Insurance Company, et al., Case No. 3:20-cv-03445-MMC (N.D. California). The
plaintiffs are Julie Grundstrom and David Merritt (“Plaintiffs”). The defendants
are Wilcac Life Insurance Company, Wilton Reassurance Life Company of New York,
and Texas Life Insurance Company (“Defendants”). The Settlement Administrator is
Angeion Group, LLC.

Question 2

What is a class action?

Accepted Answer

In a class action, one or more people, called class representatives (in this
case, Plaintiffs Julie Grundstrom and David Merritt), sue on behalf of a group
or “class” of people who have similar claims. In a class action, the court
resolves the issues for all class members, except those who timely exclude
themselves from the settlement class.

Question 3

What is this lawsuit about?

Accepted Answer

The Action alleges that Defendants terminated Class Policies without complying
with all provisions of California Insurance Code Sections 10113.71 and 10113.72,
and that, as a result, the Class Policies never lapsed and remain in force. You
can review a copy of the operative Third Amended Complaint on the Important
Documents [important-documents] page of this Settlement Website. The Action is
also described in the Settlement and Release Agreement.

Defendants deny all allegations of wrongdoing. The Court has not determined who
is right. However, the Parties have agreed to settle this Action to avoid
uncertainties and expenses associated with further litigation.

Question 4

Why is there a Settlement?

Accepted Answer

The Court has not decided whether Plaintiffs or Defendants should win this case.
Instead, the Parties have agreed to a Settlement. That way, they avoid the
uncertainties and expenses associated with further litigation, and Class Members
will receive relief under the Settlement sooner rather than, if at all, after
the completion of a trial.

Question 5

How do I know if I am in the Class?

Accepted Answer

The “Class” is defined as including:

> All owners and beneficiaries (where the Insured has died as of the date of
> July 31, 2026) of individual life insurance policies issued or delivered in
> California by Wilton, or issued or delivered outside of California by Wilton
> where the Policy Owner resided in California on the Final Lapse Date, that:
> (i) lapsed or terminated during the Class Period for nonpayment of the amount
> due without the benefit of one or more of the requirements of California
> Insurance Code Sections 10113.71 and 10113.72; (ii) have a Maturity Date that
> did not expire prior to the Insured’s death, or if the Insured is still
> living, prior to July 31, 2026; and (iii) were not affirmatively canceled or
> terminated in writing by the Policy Owner.

The Class includes:

* All living Policy Owners of a Class Policy (or if the Policy Owner of a Class
   Policy is deceased, that Policy Owner’s successor in interest) where the
   Insured under the Class Policy is living as of July 31, 2026 (the “Alive
   Population”); and
 * All Policy Owners and beneficiaries of a Class Policy where the Insured under
   the Class Policy is deceased as of July 31, 2026 (the “Deceased Population”).

For purposes of this Settlement, “Wilton” means any Defendant, and their
respective predecessor(s) under the Class Policy, but only to the extent one of
the Defendants was the insurer under the Class Policy as of the Final Lapse
Date. “Class Period” means the period from January 1, 2013, through July 31,
2026.

FAQs

Basic Information

Who Is Included in the Settlement?

The Settlement Relief

How to Get Settlement Relief

Remaining in the Settlement

The Release, Discharge and Covenant Not To Sue Under the Settlement Agreement

The Lawyers Representing You

Excluding Yourself from the Settlement

Objecting to the Settlement

The Court's Fairness Hearing

Obtaining More Information

Basic Information

1. Why was this Notice issued?

2. What is a class action?

3. What is this lawsuit about?

4. Why is there a Settlement?

Who Is Included in the Settlement?

5. How do I know if I am in the Class?

The Settlement Relief

6. What relief does the Settlement provide?

7. What is Injunctive Relief?

8. What is Damages Relief?

9. Can I contest my relief, and when will I get my relief?

How to Get Settlement Relief

10. How do I get relief?

Remaining in the Settlement

11. What am I giving up if I stay in the Settlement Class?

12. What happens if I do nothing at all?

The Release, Discharge and Covenant Not To Sue Under the Settlement Agreement

13. What does the Release say?

The Lawyers Representing You

14. Do I have a lawyer in the Action?

15. How will the lawyers be paid?

Excluding Yourself from the Settlement

16. How do I get out of the Settlement?

17. If I do not exclude myself, can I sue Defendants for the same thing later?

18. If I exclude myself, can I get anything from this Settlement?

Objecting to the Settlement

19. How do I object to the Settlement?

20. What is the difference between objecting to the Settlement and excluding myself from the Settlement Class?

The Court's Fairness Hearing

21. When and where will the Court decide whether to approve the Settlement?

22. Am I required to attend the Fairness Hearing?

23. May I speak at the Fairness Hearing?

Obtaining More Information

24. Where do I obtain more information?