Kvirikashvili v. United States Fire Insurance Company;
Blue Star Claims, LLC, et al

NOTICE OF CLASS ACTION SETTLEMENT
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Kvirikashvili v. United States Fire Insurance Company; Blue Star Claims, LLC, et al
No. 2:25-cv-05474-GAM
A federal court authorized this notice. This is not a solicitation from a lawyer

You may have received an email regarding the proposed Settlement in the above referenced litigation. This notice provides more detail regarding the Settlement. Your legal rights will be affected by the Settlement. Please read this notice carefully. It explains the lawsuit, the settlement, and your legal rights, including the process for receiving a settlement check or waiver of a lien, excluding yourself from the Settlement, or objecting to the Settlement. If you are currently represented by a lawyer in connection with an insurance claim with Blue Star Claims, LLC and United States Fire Insurance Company, please share this notice with your attorney.

• Records indicate that you are a Pennsylvania resident who was covered under an Occupational Accident Insurance policy issued by United States Fire Insurance Company (“USFIC”) as a DoorDash delivery driver and, during the period September 23, 2021 through March 26, 2026, you received a letter from USFIC’s claims administrator, Blue Star Claims, LLC (“Blue Star”), asserting a lien or seeking subrogation in connection with a Pennsylvania motor vehicle accident (“Lien Letters”).

• In this lawsuit, the Plaintiff, on behalf of a class, alleges that USFIC and Blue Star (together, “Defendants”) asserted subrogation and lien rights against personal injury recoveries in violation of Pennsylvania law. Defendants deny that they violated the law in any fashion but have agreed to settle the lawsuit to avoid the time, expense, and uncertainty associated with further litigation.

• As part of the Settlement, Defendants have agreed to refund money returned by Settlement Class Members under Lien Letters (“Returned Amount”) or waive outstanding liens under the Lien Letters (“Non-Returned Amount”), as applicable.

• The Court still has to decide whether to approve this Settlement, which may take some time.

DO NOT ADDRESS ANY QUESTIONS ABOUT THE SETTLEMENT TO THE COURT OR THE CLERK’S OFFICE. THEY ARE NOT PERMITTED TO ANSWER YOUR QUESTIONS.

YOUR LEGAL RIGHTS & OPTIONS IN THIS SETTLEMENT
Do Nothing Or Seek Review Of Amounts Cash Payment or Non-Cash Payment. If you do nothing, you are eligible to receive either a Cash Payment by Settlement Check for your portion of the Returned Amount, or a waiver of a claim to your portion of the Non-Returned Amount, as applicable. You will release any claim you may have against Defendants. If you believe that the portion of the Returned Amount or Non-Returned Amount attributed to you is not accurate, you may notify the administrator of the Settlement and seek a review. The administrator will review your submission and determine the amount to be used for your Settlement benefit.
Exclude Yourself If you exclude yourself from the Settlement, you will not receive any monetary payment. By excluding yourself, you will not release any claim you may have against Defendants.
Object You may tell the Court why you believe the Settlement should not be approved. If the Settlement is not approved, no one will be paid.

Important Dates for Class Members

Request Exclusion: September 10, 2026

Object to the Settlement: September 10, 2026

Seek Review: September 10, 2026

Fairness Hearing: November 4, 2026, at 1:30 p.m.