You and other potential class members received notice because you were a patient at Gary Motykie, M.D., Gary Motykie, M.D. A Medical Corporation, Motykie MD Skincare, LLC, or Surgery On Sunset, Inc. (collectively “Defendants”).
The notice contains important information about your privacy rights in connection with the lawsuit Jane Does One through Six, et al. v. Gary Motykie, M.D., Gary Motykie, M.D., A Medical Corporation, Motykie MD Skincare, LLC, and Surgery On Sunset, Inc. pending before the Superior Court of the State of California, Los Angeles County (Case No. 23STCV13325). This is not a lawsuit against you, and you are not being sued. The sending of this notice has been approved by the Superior Court of the State of California, Los Angeles County..
The purpose of this notice is to give you an opportunity to opt-in to the disclosure of your name, address, telephone number, and email address (“Contact Information”) to the lawyers representing the Plaintiffs.
The lawsuit is brought by Plaintiffs individually and on behalf of a putative class. The putative class is comprised of those patients of Defendants who Plaintiffs allege had Highly Sensitive Information (potentially including documenting “before” and “after” photos and personal identifying information, such as names, addresses, birthdates, contact details, credit card numbers, Social Security Numbers, and medical records) exfiltrated by cybercriminals from Defendants’ computer systems and viewed by cybercriminals and the general public (“Data Breach”). Further, Plaintiffs allege that Defendants did not properly safeguard Plaintiffs’ and putative class members’ Highly Sensitive Information, and as a result, cybercriminals were able to infiltrate Defendants’ computer systems; take Plaintiffs’ and putative class members’ Highly Sensitive Information; use the Highly Sensitive Information to demand ransoms; and publish Plaintiffs’ and putative class members’ Highly Sensitive Information on publicly-available websites. Defendants deny Plaintiffs’ allegations.
Plaintiffs and Defendants are investigating the facts of the case and the Court has not ruled on the merit of Plaintiffs’ claims or Defendants’ defenses. As part of this investigation, Plaintiffs and their counsel have requested that Defendants provide the Contact Information for all potential class members affected by the Data Breach.
If you would like to allow Defendants to disclose your Contact Information to Plaintiffs’ counsel, the Court requires you to opt-in. Your decision will NOT affect your rights under the lawsuit.
You have two possible choices:
Option One: If you want to opt-in to have your Contact Information (name, address, telephone number, and email address) disclosed to Plaintiffs’ counsel, you must provide the required information in the online opt-in form. You may also download a copy of the form HERE and mail the completed form to PO Box 3637, Baton Rouge, LA 70821. Opt-in forms must be submitted online or postmarked no later than September 23, 2025.
Option Two: If you do nothing, your Contact Information will not be made available to Plaintiff’s counsel.
Regardless of your decision, you are not required to speak with Plaintiffs’ or Defendants’ attorneys, paralegals, or investigators.
Questions? Contact the Notice Administrator by calling 1-844-871-7131.