Zakarian, et al. v. The Rawlings Company, LLC, et al.

UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI

If You Were A Missouri Citizen, Since January 1, 2019, or Kansas Citizen, Since January 1, 2021, Who Had A Medicare Advantage Organization Medical Lien Recovered or Subrogated by The Rawlings Company LLC and/or Its Affiliates
This Class Action May Affect Your Rights

  • Please read the Notice carefully as a class action lawsuit may affect your rights.
  • The Notice provides you with information regarding a class action lawsuit filed against The Rawlings Company LLC, Rawlings Financial Services, LLC, and Rawlings & Associates, PLLC (“Rawlings” or “Defendants”) over the recovery or subrogation of Medicare Advantage Organization medical liens relating to physical injuries sustained by Missouri or Kansas citizens. Your legal rights may be affected whether or not you take action.
  • The Court has issued an order allowing the lawsuit to proceed as a class action that includes various individuals who had a Medicare Advantage Organization medical lien recovered or subrogated, without the offset of procurement costs, by Rawlings for Missouri citizens since January 1, 2019, and Kansas citizens since January 1, 2021 (hereafter referred to as the “Class Members” or the “Class”).
  • In the lawsuit, Plaintiffs claim that Rawlings has failed to follow federal law for the application of a “procurement costs” offset when recovering or subrogating Medicare Advantage Organization medical liens.
  • The Court has not yet concluded that Rawlings did anything wrong. There has been no award of damages yet, and whether any money becomes available to anyone will depend on the outcome of this lawsuit.
  • The Plaintiffs must prove their breach of contract and negligence per se claims against Rawlings at a trial. Rawlings denies wrongdoing and alleges it was contractually allowed to not offset “procurement costs” and complied with all applicable laws and regulations.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

Action Summary of Legal Rights
Do Nothing You will stay in this class action lawsuit. Await the outcome. And share in the benefits, if any become available.

By doing nothing, you will remain a Class Member and will keep the right to recover money and other benefits that may result from a trial or a settlement. If you remain in the Class, however, you will give up any rights to sue Rawlings on your own about the same legal claims at issue in this lawsuit, and you will be bound by judgment.
Exclude Yourself Exclude yourself from this lawsuit. You will get no benefit from it. But you will retain the right to retain your own attorney and to sue Rawlings on your own.

If you request to be excluded from this class action lawsuit, and if any money or benefits later become available, you will not be eligible to share in those benefits. However, you will keep any rights to sue Rawlings on your own about the same legal claims in this lawsuit.
  • These rights and options—and the deadlines to exercise them—are explained in more detail in the Notice. To be excluded, you must act before September 21, 2026.