FORD v. VETERANS GUARDIAN VA CLAIM CONSULTING, LLC

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IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
JENNIFER FORD, ERIC BEARD, and ) BRIAN OTTERS, individually and on )
behalf of all others similarly situated, )
)
Plaintiff,
) ) )
V.
1:23-CV-756
)
VETERANS GUARDIAN VA CLAIM ) CONSULTING, LLC, )
)
Defendant. )
MEMORANDUM OPINION AND ORDER
Catherine C. Eagles, Chief District Judge.
In this consumer protection case, the Court granted the plaintiffs' motion for class certification as to their claims that the defendant, Veterans Guardian VA Claim Consulting, LLC, charges illegal fees for assisting veterans with applications for disability compensation. The parties have filed a joint submission on class notice and notice procedures, identifying areas of agreement and disagreement. Upon consideration of the materials submitted by the parties and in light of the Court's experience, the Court approves the attached notices.
I. Relevant Procedural History and Facts
Plaintiffs Jennifer Ford, Eric Beard, and Brian Otters are disabled military veterans who retained Guardian to assist them in obtaining or increasing their disability compensation. Doc. 52 at 11 57-58, 65, 111-12, 120, 138-39, 144. Federal law prohibits charging a fee in connection with the filing of an initial disability claim before
AUTHENTICATED U.S. GOVERNMENT INFORMATION GPO
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the Veterans Administration. 38 U.S.C. § 5904(c)(1). While fees are permitted later in
the claims process, “no individual may act as an agent or attorney in the preparation,
presentation, or prosecution of any claim under laws administered by the Secretary unless
such individual has been recognized for such purposes by the Secretary.” Id. § 5901(a);
see also 38 C.F.R. § 14.629(b)(1) (“No individual may assist claimants in the preparation,
presentation, and prosecution of claims for VA benefits as an agent or attorney unless he
or she has first been accredited by VA for such purpose.”); 38 C.F.R. § 14.636(c)(1)(i)
(“Agents and attorneys may charge claimants or appellants for representation provided
after . . . notice of an initial decision on the claim . . . .”).
The plaintiffs contend that Guardian violates federal law by offering these services
for a fee and without accreditation and that the fees it charges for those services are
illegal and violate the North Carolina Unfair and Deceptive Trade Practices Act and the
North Carolina Debt Collection Act. Doc. 52 at ¶¶ 188, 225, 313. The Court granted the
plaintiffs’ motion for class certification and certified three classes. Doc. 131 at 27. The
classes as certified consist of:
(1) UDTPA Initial Claim Class: All veterans who made their
first payment to Veterans Guardian in connection with an initial
claim for VA Disability Compensation under a consulting
contract substantially similar to Exhibit A to the Consolidated
Complaint between August 23, 2019, and the date of this
Court’s order approving class notice.
(2) UDTPA Non-Initial Claim Class: All veterans who made
their first payment to Veterans Guardian in connection with a
non-initial claim for VA Disability Compensation under a
consulting contract substantially similar to Exhibit A to the
Consolidated Complaint between August 23, 2019, and the
date of this Court’s order approving class notice.
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(3) NCDCA Class: All veterans who, between August 23,
2019, and the date of this Court’s order approving class notice,
were sent an invoice by Veterans Guardian in connection with
a claim for VA Disability Compensation in substantially the
same form as Exhibit B to the Consolidated Complaint and
who made a payment to Veterans Guardian.
Id. Class representatives were appointed for each class and the interim lead class counsel
for the plaintiffs was appointed as class counsel. Id. at 28.
II. 	Notice Required to the Classes
The classes were certified under Federal Rule of Civil Procedure 23(b)(3), and
notice to class members is required. See Fed. R. Civ. P. 23(c)(2)(B). Notice gives class
members “an opportunity to opt-out of the class at the certification stage.” Krakauer v.
Dish Network, LLC, 925 F.3d 643, 655 (4th Cir. 2019). Generally speaking, for the
results of a damages class action to bind an absent class member, notice to the class must
provide “minimal procedural due process protection.” Phillips Petroleum Co. v. Shutts,
472 U.S. 797, 811–12 (1985). Rule 23(c)(2)(B) requires “the best notice that is
practicable under the circumstances, including individual notice to all members who can
be identified through reasonable effort.” Fed. R. Civ. P. 23(c)(2)(B).
III. 	The Proposed Notices
Pursuant to court direction, Doc. 131 at 28, the parties met and consulted on the
form and method of providing class notice and filed a joint submission directed to notice
and scheduling. Doc. 134. They agree to a large extent, but not completely. Id. Each
has submitted dueling proposals reflecting those agreements and disagreements. See
Docs. 134-6,134-7.
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A. Notice Administrator
The parties agree that American Legal Claim Services, LLC, a company that
specializes in class notice administration, will disseminate the notices using contact
information for class members provided from Guardian’s records. Doc. 134 at 3–5. The
Court has reviewed its qualifications, and American Legal is an appropriate notice
administrator.
B. Class Website
The parties agree that it is appropriate for the notice administrator to work with the
parties to create and maintain a class website. Id. at 5. They agree that the website will
include substantive court documents in the case including the operative complaint,
Guardian’s answer, the Court’s opinion on class certification, and the Court’s order
approving class notice. Id. at 6. And finally, they agree that the class notice sent to
potential class members will direct potential class members to the website for additional
information. See id. at 5.
Many class actions use similar websites to inform potential class members of
ongoing litigation. See, e.g., Lewis v. Equityexperts.org, LLC, No. 22-CV-302, 2025 WL
2264491, at *2 (E.D.N.C. Aug. 7, 2025) (stating that “district courts in this circuit have
used class action websites to facilitate notice.”). The proposed public website is a
reasonable and relatively inexpensive way to provide information to class members and is
a good supplement to more personal notice provided in other ways. See discussion infra
(addressing email and postcard notice).
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In addition to the matters identified by the parties, the public website should
include access to future key court orders such as scheduling orders, Daubert orders,
summary judgment orders, and the like. Housekeeping orders such as motions to extend
time and other non-substantive logistical matters need not be posted.
With this addition, the use of the proposed class website is approved.
C. Method of Individual Notice
Guardian’s client records contain contact information for members of all three
classes. Doc. 131 at 9, 21. The parties agree that all class members should be notified by
email, using the contact information in Guardian’s possession. Doc. 134 at 2. The
plaintiffs propose that notice be sent by postcard only when email notice is not delivered.
Id. The defendant proposes that notice be sent to all class members by email and
postcard. Id.
Rule 23 allows notice by “United States mail, electronic means, or other
appropriate means.” Fed. R. Civ. P. 23(c)(2)(B). In 2018, subdivision (c)(2) was
amended “to recognize contemporary methods of giving notice” and “to make notice
more effective.” See Fed. R. Civ. P. 23(c)(2) advisory committee’s note to 2018
amendment. The committee note suggests that when a court selects the method or a
combination of methods for giving notice it “should consider the capacity and limits of
current technology, including class members’ likely access to such technology.” Id.
Here, the record shows that Guardian and class members regularly communicated
through email. See e.g., Doc. 106-7 (Guardian’s email confirming payment). There is
nothing to indicate that Guardian’s records of email addresses are outdated or incorrect.
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Indeed, Guardian is motivated to keep them current, if for no other reason so that it can
inexpensively bill clients via email. Class members are not likely to consider an email
about Guardian to be junk email, since such emails would ordinarily be directed to
matters about their disability claims. It is highly likely that email notice will reach class
members.
Postcard notice is appropriate for any class members whose email comes back as
undeliverable. But duplicate notice to every class member by postcard, as Guardian
proposes, will substantially increase the costs of this class action with little benefit to the
notice process. Email notice is “the best notice that is practicable under the
circumstances.” Fed. R. Civ. P. 23(c)(2)(B). Back-up notice by postcard is an
appropriate supplement when an email is undeliverable.
Guardian’s proposed notice directs class members to call one of class counsel’s
offices to receive information about the case. Doc. 134-6 at 6. The record does not
reflect the opinion of the plaintiffs on the inclusion of the number. Notice, as agreed,
directs class members to contact class counsel via email. Id. at 6–9. A phone number is
not needed because the class members have other ways to learn about the case and they
can ask questions via email.
In sum, notice shall be sent by email with postcard backup for undeliverable
emails. The notice administrator shall maintain a class website with substantive court
documents. The agreed upon notice includes email contact information for class counsel,
so it need not include a toll-free number class members can call.
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IV. 	Effectuating Notice
Guardian needs five business days after the Court’s order approving the notice
plan to provide the relevant class contact data to the notice administrator. Doc. 134 at 6
n.1. The notice administrator can issue notice to the class members within 30 days of
receiving the data from Guardian. Id. Nothing else appearing, then, the class notice
should be sent no later than March 19, 2026, which allows time for these tasks to be
completed.
The plaintiffs ask that initial notice be sent promptly, once these logistical tasks
are completed. Id. at 7. Guardian asks that notice be delayed while its petition for a Rule
23(f) interlocutory appeal is resolved by the United States Court of Appeals for the
Fourth Circuit. Id. at 9. As that petition has now been resolved and the interlocutory
appeal denied, see Doc. 143-1, there is no reason to wait.
Within five business days from this order, Guardian shall provide the relevant
class data to the notice administrator. No later than March 19, 2026, the notice
administrator shall send email notice. The notice administrator shall send postcard
backup notice within five days of receiving word that the email was undeliverable.
V. 	Content of the Notices
Rule 23(c)(2)(B) states that:
[t]he notice must clearly and concisely state in plain, easily understood
language:
(i) the nature of the action;
(ii) the definition of the class certified;
(iii) the class claims, issues, or defenses;
(iv) that a class member may enter an appearance through an attorney
if the member so desires;
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(v) that the court will exclude from the class any member who requests
exclusion;
(vi) the time and manner for requesting exclusion; and
(vii) the binding effect of a class judgment on members under Rule
23(c)(3).
Fed. R. Civ. P. 23(c)(2)(B). The parties largely agreed on the language and wording of
the notices, with some petty stylistic differences and a couple of more meaningful
disagreements.
A. Matters of Agreement
The notices as jointly proposed, Docs. 134-6, 134-7, and as adopted herein clearly
and concisely state in plain language the nature of the action and the class claims, issues,
and defenses. Exhibit A at 4; Exhibit B at 2; Fed. R. Civ. P. 23(c)(2)(B)(i), (iii). The
email notice provides the class definitions, Exhibit A at 6, and the postcard notice directs
class members to the class website, where they can easily find the class definitions.
Exhibit B at 2; Fed. R. Civ. P. 23(c)(2)(B)(ii).1 The email and postcard notices state that a
class member may hire an attorney at his or her own expense and that the attorney may
enter an appearance in the case. Exhibit at A at 7–8; Exhibit B at 2; Fed. R. Civ. P.
23(c)(2)(B)(iv). The notices clearly state that the Court will exclude from the class any
member who requests exclusion, Exhibit A at 2, 6–7; Exhibit B at 2, and provide the time
and manner for requesting exclusion. Exhibit A at 6–7; Exhibit B at 2; Fed. R. Civ. P.
23(c)(2)(B)(v)-(vi). The notices specify that members of the class will be bound by the
1 There is not room on the postcard to include the three class definitions.
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class judgment if they do not opt out through an exclusion request by a specific date.
Exhibit A at 7; Exhibit B at 2; Fed. R. Civ. P. 23(c)(2)(B)(vii).
The parties have agreed on language that meets all of these requirements, and they
disagree only around the fringes.
B. Opting Out
Rule 23(c)(2)(B)(vi) requires that the notice clearly state “the time and manner for
requesting exclusion.” Fed. R. Civ. P. 23(c)(2)(B)(vi). The parties agree on the manner
for requesting exclusion: by sending an email or a written Statement of Exclusion to the
notice administrator. This is an appropriate manner to request exclusion, and the notices
are clear as to how such requests must be communicated and what such requests must
include. Exhibit A at 6–7; Exhibit B at 2.
The parties also agree on the timing for opting out: 45 days to opt-out of the
action from the dissemination of the notices. Doc. 134 at 6 n.1. The Court agrees that a
45-day period is sufficient to protect the due process rights of any absent class members
who do not want to be bound by the action. It allows plenty of time for receipt and
review of the notice, for an appropriate investigation, and for an opt-out letter to be
prepared and mailed. Senders of emails that are undeliverable usually are informed very
quickly, so the notice administrator can send postcard notices soon thereafter and the
recipients should still have around a month to opt-out.
As provided supra, the email notices will go out no later than March 19, 2026.
With 45 days to opt out, the opt-out deadline is set for May 4, 2026. That date shall be
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included in the email and postcard notice so class members will know exactly when their
opportunity to opt-out ends.
C. Other Disagreements
The plaintiffs propose including in the notice an approximate total amount
Guardian collected in fees from class members during the class period, Doc. 134-6 at 4,
and the fact that the class members will not incur costs or expense. Id. at 6, 8. Guardian
did not include this information in its proposed notice. Neither party addressed why this
information is or is not appropriate in their section of the joint submission.2
This information shall be included in the email notice because it provides useful
information to class members that may affect their decision on whether to opt-out of the
class. Understanding the scope of Guardian’s fee collection and the fact that they will not
incur costs upon the outcome may assist class members in taking the notice seriously and
understanding the potential ramifications and benefits of class membership. They will be
better informed as they make a decision on whether to opt out.
The Court will not address the disagreements the parties have over capitalization,
grammar correction, or naming conventions. The Court resolves those non-substantive
details without further discussion and as shown in the approved notices attached hereto.
As approved, the notices are clear and easy to read.
2 In their motion to seal, the plaintiffs assert that the total amount the defendant collected
from class members during the class period provides valuable information to class members for
their opt-out decision. Doc. 135 at 2.
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VI. 	Conclusion
The Court finds that the attached notices provided by email with postcard backup
for undeliverable emails and website (a) constitute the best notice practicable under the
circumstances; (b) are reasonably calculated, under the circumstances, to reach class
members; (c) describe the nature of the case, certified class, claims, attorney
representation, opt-out procedure, and effect of judgment; (d) are reasonable and
constitute due, adequate, and sufficient notice to all persons entitled to receive such
notice; and (e) satisfy all applicable requirements of the Federal Rules of Civil Procedure,
the Due Process Clause of the United States Constitution, and all other applicable law
and rules.
The Court will enter a scheduling order addressing other matters separately, as
time permits.
It is ORDERED that:
1. 	The attached notices are APPROVED, with dates and other blanks to be filled
in consistent with this order.
2. 	Guardian SHALL provide class data within five business days of this order.
3. 	The notice administrator SHALL send the approved email notices as quickly
as possible and no later than March 19, 2026.
4. 	The notice administrator SHALL send postcard backup notice within five days
of receiving an undeliverable email notice.
5. 	The notice administrator SHALL maintain a public website where this Order,
the Class Certification Order, the approved Notice, and all other substantive
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orders shall be posted. Class counsel SHALL keep the notice administrator
informed of such developments.
6. 	No later than April 2, 2026, class counsel or the notice administrator SHALL
file a report showing that the notices were emailed and, where necessary,
mailed via postcard and that the website is available.
7. 	No later than May 22, 2026, class counsel or the notice administrator SHALL
file a report otherwise showing compliance with this order and providing
details on the number of undeliverable notices and the number of class
members choosing to opt-out.
This the 9th day of February, 2026.
___________________________________
UNITED STATES DISTRICT JUDGE
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Exhibit A — Email Notice

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Court Approved Legal Notice
United States District Court for the
Middle District of North Carolina
Jennifer Ford, et al. v. Veterans Guardian VA Claim Consulting, LLC
Case No. 1:23-CV-00756-CCE-LPA
If you are a veteran who retained Veterans Guardian VA Claim Consulting, LLC (“Veterans
Guardian”) to assist you in obtaining or increasing your disability compensation and, on or
after August 23, 2019, either made your first payment to Veterans Guardian or were sent an
invoice by and made a payment to Veterans Guardian, a class action lawsuit may affect your
legal rights.
This is not a solicitation from a lawyer. You are not being sued.
To review documents that will provide more information
about this class action lawsuit, you may visit:
[class website]
You could be a member of a Class Action. If you are a Class Member, your legal rights are affected
whether you act or do not act, so please read this Notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IF YOU ARE A CLASS MEMBER
Do Nothing and
Automatically Be Part of the
Class
You are automatically part of the Class if you satisfy any of
the three Class definitions set forth below in Section 5. 	If
you receive this Notice, Guardian has provided information
tending to indicate that you are a member of one or more
Classes.
Exclude Yourself by [DATE],
2026 You may request to be excluded from the Class. This is also
referred to as “opting out.” 	If you request to be excluded,
you will not be part of the lawsuit and you will not be able
to 	receive 	any 	money 	or 	benefits 	from 	any 	potential
settlement or judgment. You also will not be bound by any
judgment adverse to the Class if you request to be excluded
from the Class.
If you decide you do not want to participate in this class
action lawsuit and you do not make a timely request for
exclusion as described in this Notice, you will still be bound
by any judgment.
• 	These rights and options—and the deadlines to exercise them—are explained in this Notice.
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BASIC INFORMATION .............................................................................................................. 3–5
1. 	Why is there a Notice?
2. 	What is this lawsuit about?
3. 	Why is this a class action?
4. 	How do I get more information?
5. 	I am still not sure I am included, what is the class definition?
THE STATUS OF THE LAWSUIT..................................................................................................5
6. 	What are the legal claims being alleged against Veterans Guardian in this lawsuit?
REMAINING IN THE CLASS.........................................................................................................5
7. 	What happens if I do nothing at all?
EXCLUDING YOURSELF FROM THE CLASS......................................................................5–6
8. 	How do I exclude myself from the Class?
9. 	If I don’t exclude myself, can I sue Veterans Guardian for the same thing later?
10. If I exclude myself, can I get money from this case?
THE LAWYERS REPRESENTING CLASS MEMBERS.............................................................6
11. Do I have a lawyer in this case?
OBTAINING MORE INFORMATION..........................................................................................7
12. How do I obtain more information?
WHAT THIS NOTICE CONTAINS
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BASIC INFORMATION
If you received a Notice by email, records collected by Veterans Guardian VA Claim Consulting,
LLC (“Veterans Guardian”) show that you may have retained Veterans Guardian to assist you in
obtaining or increasing your VA disability compensation.
This Notice is intended to advise you of a class action lawsuit against Veterans Guardian and of
your rights and options, including your right to exclude yourself from the Class and from
further proceedings in this action if you wish to do so.
Chief District Judge Catherine C. Eagles of the United States District Court for the Middle District
of North Carolina is overseeing this lawsuit. 	The lawsuit is known as Jennifer Ford, et al. v.
Veterans Guardian VA Claim Consulting, LLC, and the case number is 1:23-CV-00756-CCE-
LPA.
Federal law restricts those individuals who may act as an agent or attorney in preparing, presenting,
and/or prosecuting disability claims for benefits before the Department of Veterans Affairs (“VA”)
to persons or entities meeting specific qualifications and accreditation requirements. 	Plaintiffs
allege that Veterans Guardian violates federal law by offering its VA disability claim services
without VA accreditation and that it charges illegal fees in violation of the North Carolina Unfair
and Deceptive Trade Practices Act (“UDTPA”) and the North Carolina Debt Collection Act
(“NCDCA”). 	Under their UDTPA Classes, Plaintiffs are seeking damages from Veterans
Guardian in an amount equal to three times all amounts paid to Veterans Guardian by Class
Members. During the Class period, Veterans Guardian collected more than $250,000,000.00 from
Members of the Classes. Additionally, under the NCDCA Class, Plaintiffs are seeking damages
from Veterans Guardian in an amount equal to all amounts paid to Veterans Guardian by Class
Members, plus civil penalties as the Court may allow, but not less than five hundred dollars ($500)
nor greater than four thousand dollars ($4,000) for each NCDCA violation. Plaintiffs also seek
recovery of litigation costs and attorneys’ fees under the North Carolina statutes at issue.
Veterans Guardian denies that it violates federal or North Carolina law. 	In particular, it denies
that it acted as an agent or attorney for veterans in assisting them with VA disability benefits
claims.
The Court has not decided whether Veterans Guardian did anything wrong. 	The case is
continuing. 	There is no money or benefits that have been obtained for the Class, and there is no
guarantee there will be in the future.
In a class action, one or more persons called class representatives sue on behalf of persons who may
1. 	Why is there a Notice?
2. 	What is the lawsuit about?
3. 	Why is this a class action?
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have the same legal claim. All the people who have the same legal claim collectively make up the
“Class” and are referred to individually as “Class Members.” One lawsuit before one judge and jury
resolves the issues and legal claims for all Class Members together, except for those who exclude
themselves from the Class, regardless of whether the outcome is favorable or unfavorable. Because
Plaintiffs believe the conduct alleged in this case affected a large number of veterans who were
economically injured in a similar way, Plaintiffs filed this case as a class action.
This Notice does not fully describe all the legal claims and defenses between Plaintiffs and
Veterans Guardian. The relevant legal filings and court documents in this class action lawsuit are
available at [class website] or online for a fee through the Court’s Public Access to Court
Electronic Records (“PACER”) system at http://ecf.ncmd.uscourts.gov or by visiting the office of
the Clerk of Court for the United States District Court for the Middle District of North Carolina,
located at 324 W. Market Street, Greensboro, NC 27401-2544, and available on weekdays between
8:30 a.m. and 4:30 p.m. In addition, you may contact Class Counsel at notice@vandwlaw.com.
If you wish to do so, you may also register on the website created and maintained by the Notice
Administrator—[class website]—if you want to be kept informed of the status of the case and
receive email communications from Class Counsel.
You are receiving this Notice because Veterans Guardian’s records indicate that you may be a
member of one or more of the following Classes. 	You are in the Class if you meet one of the
following three definitions and do not properly execute and file a timely request for exclusion from
the Class.
1. 	UDTPA Initial Claim Class: All veterans who made their first payment to Veterans
Guardian in connection with an initial claim for VA Disability Compensation under a
consulting contract substantially similar to Exhibit A to the Consolidated Complaint
between August 23, 2019, and the date of this Court’s order approving class notice.
2. 	UDTPA Non-Initial Claim Class: All veterans who made their first payment to Veterans
Guardian in connection with a non-initial claim for VA Disability Compensation under a
consulting contract substantially similar to Exhibit A to the Consolidated Complaint
between August 23, 2019, and the date of this Court’s order approving class notice.
3. 	NCDCA Class: All veterans who, between August 23, 2019, and the date of this Court’s
order approving class notice, were sent an invoice by Veterans Guardian in connection with
a claim for VA Disability Compensation in substantially the same form as Exhibit B to the
Consolidated Complaint and who made a payment to Veterans Guardian.
• 	Exclusions: Excluded from the Class are:
(a) any persons or other entity currently related to or affiliated with Veterans
Guardian; and
4. 	How do I get more information?
5. 	I am still not sure if I am included, what are the Class definitions?
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(b) any Judge presiding over this action and members of his or her immediate
family.
If you are still not sure whether you are included in the Class, please go to [class website].
THE STATUS OF THE LAWSUIT
The Court is allowing this class action case to proceed for a determination on the merits with
respect to alleged violations of the North Carolina Unfair and Deceptive Trade Practices Act and
the North Carolina Debt Collection Act by Veterans Guardian. A trial date is yet to be scheduled.
REMAINING IN THE CLASS
If you fall within one of the three Class definitions (see Question 5) and you do nothing, you will
stay in this lawsuit and your legal rights will be determined in this lawsuit. 	If you stay in this
lawsuit and Plaintiffs win, you will be notified about how to seek money or other benefits from
this lawsuit. 	If Plaintiffs lose this lawsuit, you will not receive any money or other benefits.
However, there is no claim that has been advanced that would require you to incur any costs or
expenses if Plaintiffs lose this case. If you do nothing now, regardless of whether Plaintiffs win
or lose, you will be legally bound by the orders the Court issues and judgments the Court enters in
this class action lawsuit.
Please advise the Class Notice Administrator of any changes to your email or postal mailing
address so that information can be emailed or mailed to you if there is a judgment or settlement in
this lawsuit in the future. 	Contact information for the Class Notice Administrator is listed in
Section 12 below.
EXCLUDING YOURSELF FROM THE CLASS
If you do not want to be a part of the Class for any reason, including that you would rather keep
your right to sue or continue to sue Veterans Guardian on your own regarding the facts and legal
issues in this case, then you must take steps to get out of the Class. 	This is called excluding
yourself—or is sometimes referred to as “opting out” of the Class.
To exclude yourself from the Class you must send an email or letter by U.S. mail saying that you
want to be excluded from Jennifer Ford, et al. v. Veterans Guardian VA Claim Consulting, LLC.
Be sure to include your full name, mailing address, telephone number, email address, and your
signature.
If excluding yourself via Email: You must email your exclusion to ____________ by [DATE],
2026.
6. 	What are the legal claims being alleged against Veterans Guardian in this lawsuit?
7. 	What happens if I do nothing at all?
8. 	How do I exclude myself from the Class?
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If excluding yourself via U.S. Mail: 	You must mail your exclusion request, postmarked by
[DATE], 2026, to:
Ford v. Veterans Guardian Class Action Exclusion
Ford v. Veterans Guardian
c/o American Legal Claims Services, LLC
PO Box 23489, Jacksonville, FL 32241
To be effective, your exclusion request must be emailed or postmarked no later than [DATE],
2026.
If you timely ask to be excluded, you will not be legally bound by anything that happens in this
lawsuit. You may be able to sue (or continue to sue) Veterans Guardian in the future.
If you do not request exclusion from the Class by [DATE], 2026, and you fall within the definition
of any one of the three Classes listed in Section 5 above, you will be legally bound by any final
judgment or settlement in this lawsuit. If you wish to remain a Class Member, you are not required
to do anything at this time.
No. 	Unless you exclude yourself, you give up the right to sue Veterans Guardian for the same
legal claims that are a part of this lawsuit. If you have a pending lawsuit, speak to your lawyer in
that lawsuit immediately. 	You must exclude yourself from this lawsuit to continue your own
lawsuit. Remember, the exclusion deadline is [DATE], 2026.
No. If you exclude yourself, and the Court awards money damages to the Class Members after
trial or if there is a settlement of this lawsuit, you will not be entitled to any money or benefits.
But, you may sue, continue to sue, or be part of a different lawsuit against Veterans Guardian.
THE LAWYERS REPRESENTING CLASS MEMBERS
The Court has appointed Janet R. Varnell, Brian W. Warwick, Christopher J. Brochu, Pamela G.
Levinson, and Varnell & Warwick, P.A. and Shanon J. Carson, Jeff Osterwise, Radha Nagamani
Raghavan, and Berger Montague PC as Class Counsel to represent you and other Class Members
in this class action lawsuit. 	You will not be charged for these lawyers. You may contact Class
Counsel by email at notice@vandwlaw.com.
Any fees or costs ultimately allowed by the Court to be paid to Class Counsel will be paid by the
Defendant as ordered by the Court or out of any funds awarded to 	the Class because of a
settlement or judgment in this class action lawsuit.
If you want to be represented by your own lawyer, you may hire one at your own expense. If that
11. Do I have a lawyer in this case?
9. If I don’t exclude myself, can I sue Veterans Guardian for the same thing later?
10. If I exclude myself, can I get money from this case?
Case 1:23-cv-00756-CCE-LPA Document 147 Filed 02/09/26 Page 19 of 23

7
lawyer wishes to participate in this class action lawsuit, that lawyer must enter an appearance on
your behalf and at your expense. Otherwise, you will be represented by Class Counsel along with
Plaintiffs and all other Class Members.
OBTAINING MORE INFORMATION
Mailing Address:
Ford v. Veterans Guardian
c/o American Legal Claims Services, LLC
PO Box 23489, Jacksonville, FL 32241
You can also visit the website [class website], which is dedicated to the lawsuit or email Class
Counsel directly at notice@vandwlaw.com.
Please do not contact the Court. 	Any questions regarding this class action lawsuit or this
Notice should be directed to the Notice Administrator or Class Counsel listed above.
12. Where do I obtain more information?
Case 1:23-cv-00756-CCE-LPA Document 147 Filed 02/09/26 Page 20 of 23

Exhibit B-— Postcard Notice

Case 1:23-cv-00756-CCE-LPA Document147 Filed 02/09/26 Page 21 of 23

This Notice contains important information about your legal rights in a class action lawsuit. Please read the entire Notice carefully.
1. What is the purpose of this Notice? This Notice was sent to you by order of the United States District Court for the Middle District of North Carolina (the “Court”). This
Notice tells you about a class action lawsuit that may affect you and your legal rights, your right to participate in the lawsuit, and your right to opt out of the lawsuit. Nothing
in this Notice should be taken as an expression by the Court of any opinion on the ultimate outcome of this lawsuit, and nothing in this Notice should be taken to mean you
would recover anything.
2. What is this lawsuit about? This lawsuit is brought by three disabled veterans on behalf of three certified classes of veterans who hired and paid Defendant Veterans
Guardian VA Claim Consulting, LLC (“Veterans Guardian”) to assist them with their claims for VA disability compensation. Plaintiffs allege that Veterans Guardian provided
claims-preparation services without required federal accreditation and charged unlawful fees, in violation of federal law, the North Carolina Unfair and Deceptive Trade
Practices Act, and the North Carolina Debt Collection Act. Veterans Guardian denies that it violates federal or North Carolina law. In particular, it denies that it acted as an
agent or attorney for veterans in assisting them with VA disability benefits claims. On December 30, 2025, the Court granted Plaintiffs’ motion for class certification. Veterans
Guardian’s records indicate that you may be a Class Member.
3. What are my options? You will remain a Class Member unless you expressly request to be excluded from this lawsuit. As a Class Member, you will be bound by the
outcome, whether the issues are decided by trial or otherwise, and whether the outcome is favorable or unfavorable. As a Class Member, any claims you might have regarding
the facts in this lawsuit cannot be pursued in any other lawsuit, unless you opt out.
If you wish to remain a member of the Class, don’t do anything and your interests and rights will be decided in this lawsuit. You will be represented by the Class
Representatives and Class Counsel. Class Members may also enter an appearance individually or through counsel of their own choosing at their own expense, but don’t
have to do so.
If you wish to opt out of the Class, you must email the Class Administrator (email below) or mail a written Statement of Exclusion to the Class Administrator (mailing
address below) postmarked by no later than [DATE], 2026. The Statement of Exclusion should state: “I hereby request to be excluded from the Class in Ford v. Veterans
Guardian VA Claim Consulting, LLC, Case No. 1:23-cv-756,” and it must be signed by the Class Member. The Statement of Exclusion should be addressed to: Ford v. Veterans
Guardian, c/o American Legal Claims Services, LLC, PO Box 23489, Jacksonville, Florida 32241. Individuals who request exclusion from the Class won’t be entitled to share
in the benefits of any settlement or judgment that may be reached, nor will they be bound by any settlement or judgment. If you elect to be excluded from the Class, you
may pursue any claims you have at your own expense.
For more detailed information, please visit the case website: [class website]
Questions about this Notice should be directed to Class Counsel by email: notice@vandwlaw.com.
Please Do Not Contact the Court with Questions
If your present address differs from the address on this Notice, or if the person to whom this Notice was addressed is deceased, please provide the Class Administrator with
an updated address or the name and address of the deceased person’s executor or personal representative. This contact information shall be provided to the Class
Administrator via email at [Class Administrator Email Address]. Please put “Change of Address” in the subject line and provide your full name, previous address, current
address, and the Notice ID from your Notice in the body of the email. You can also mail that information to: Ford v. Veterans Guardian, c/o American Legal Claims Services,
LLC, PO Box 23489, Jacksonville, Florida 32241.
Case 1:23-cv-00756-CCE-LPA Document 147 Filed 02/09/26 Page 22 of 23

Court Ordered Notice
United States District Court
Middle District of North Carolina
Jennifer.Ford?.et.al¡
v¡
Veterans.Guardian.VA
Claim.Consulting?.LLC
Case No. 1:23-cv-756
Notice of Pendency of Class Action
This Notice is to inform you of your rights
and how to get information about the
above-named class action lawsuit.
You Are Not Being Sued
This Notice describes a class action lawsuit
pending 	against 	Veterans 	Guardian 	VA
Claim 	Consulting, 	LLC 	(“Veterans
Guardian”). 	You’ve received this Notice
because 	Veterans 	Guardian’s 	records
suggest you might be a person whose rights
could be affected by this lawsuit. 	You’re
entitled to remain in this lawsuit as a Class
Member or opt out of this lawsuit as
described on reverse side.
Ford v. Veterans Guardian VA Claims Consulting, LLC
c/o Class Notice Administrator
American Legal Claims Services, LLC,
PO Box 23489, Jacksonville, Florida 32241
[class website]
To update address visit [www.caseURL.com]
Notice ID: «noticeid»
PIN: «pin»
«keyline» (Barcode)
«fname» «lname»
«addrline1» «addrline2»
«addrcity» «addrstate» «addrzip»
«country»
Case 1:23-cv-00756-CCE-LPA Document 147 Filed 02/09/26 Page 23 of 23