Naclerio v. DocGo Inc. — Entry #117: DECLARATION of Ross D

Case 1:23-cv-09476-KPF     Document 117       Filed 03/17/26   Page 1 of 4


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK


                                          x
GENESEE COUNTY EMPLOYEES’                 :   Civil Action No. 1:23-cv-09476-KPF
RETIREMENT SYSTEM, Individually and on :
Behalf of All Others Similarly Situated,  :   CLASS ACTION
                                          :
                              Plaintiff,  :   SUPPLEMENTAL DECLARATION OF
                                          :   ROSS D. MURRAY REGARDING: (A)
       vs.                                :   CONTINUED NOTICE DISSEMINATION;
                                          :   (B) UPDATE ON CALL CENTER
DOCGO INC. and ANTHONY CAPONE,            :   SERVICES AND WEBSITE; AND (C)
                                          :   REQUESTS FOR EXCLUSION RECEIVED
                              Defendants.     TO DATE
                                          :
                                          x


       Case 1:23-cv-09476-KPF          Document 117         Filed 03/17/26     Page 2 of 4


       I, ROSS D. MURRAY, declare and state as follows:

       1.      I am employed as a Vice President of Securities by Verita Global (“Verita”),

located at 1 McInnis Parkway, Suite 250, San Rafael, California. Pursuant to this Court’s

November 18, 2025 Order Preliminarily Approving Settlement and Providing for Notice (ECF

106) (the “Notice Order”), Verita was appointed as the Claims Administrator in connection with

the proposed Settlement of the above-captioned litigation (the “Litigation”).1 I oversaw the notice

services that Verita provided in accordance with the Notice Order.

       2.      I submit this declaration as a supplement to my previously filed declaration, the

Declaration of Ross D. Murray Regarding: (A) Notice Dissemination; (B) Publication; (C)
Establishment of Call Center Services and Website; and (D) Requests for Exclusion Received to

Date (ECF 114) (the “Initial Mailing Declaration”). The following statements are based on my

personal knowledge and information provided to me by other Verita employees, and, if called as

a witness, I could and would testify competently thereto.

                       CONTINUED DISSEMINATION OF NOTICE

       3.      As more fully detailed in the Initial Mailing Declaration, as of February 12, 2026,

Verita had mailed or emailed a total of 13,280 Postcard Notices and four copies of the Notice of

Pendency and Proposed Settlement of Class Action (the “Notice”) and Proof of Claim and Release

form (the “Proof of Claim”) (collectively, the “Claim Package”) to potential Class Members and
their nominees. In addition, one institution reported that they anticipated sending Postcard Notices

via email to 9,972 potential Class Members. See Initial Mailing Declaration, ¶11.

       4.      Since February 12, 2026, Verita has mailed two Claim Packages in response to

requests from potential Class Members, brokers, and nominees and as a result of mail returned as


1
  Any capitalized terms used that are not otherwise defined herein shall have the meanings ascribed
to them in the Stipulation of Settlement, dated November 12, 2025 (ECF 101-1) (the
“Stipulation”), which is available on the website established for the Settlement at
www.DocGoSecuritiesSettlement.com.
SUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED
NOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)
REQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF                                      -1-


       Case 1:23-cv-09476-KPF           Document 117        Filed 03/17/26      Page 3 of 4


undeliverable for which new addresses were identified and re-mailed to those new addresses.2

Therefore, as of March 13, 2026, Verita has mailed or emailed a total of 13,280 Postcard Notices

and six Claim Packages to potential Class Members and nominees.

       UPDATE ON CALL CENTER SERVICES AND SETTLEMENT WEBSITE

       5.      Verita continues to maintain the toll-free telephone number (1-888-808-8947) to

accommodate inquiries about the Settlement from potential Class Members. Verita also monitors

the case-dedicated e-mail address, [email protected]. Verita endeavors to

respond timely to each telephone and e-mail inquiry and will continue to respond to Class Member

inquiries via the toll-free telephone number and case dedicated e-mail address until the conclusion
of the administration.

       6.      Verita also continues to maintain the website dedicated to the Settlement,

www.DocGoSecuritiesSettlement.com (the “Settlement Website”), to assist potential Class

Members. Following Lead Counsel’s filing of their briefing in support of the Settlement on

February 17, 2026, Verita posted to the Settlement Website copies of the papers in support of the

Motion for Final Approval of Class Action Settlement and Approval of Plan of Allocation and the

Motion for an Award of Attorneys’ Fees and Expenses.              Verita will continue operating,

maintaining and, as appropriate, updating the Settlement Website until the conclusion of the

administration of this Settlement.
       REQUESTS FOR EXCLUSION AND OBJECTIONS RECEIVED TO DATE

       7.      Pursuant to the Notice Order, the Notice and Settlement Website informed potential

Class Members that written requests for exclusion from the Class were to be mailed to Verita,

postmarked or received no later than March 3, 2026. At the time of the Initial Mailing Declaration,

Verita reported that it had not received any requests for exclusion. See Initial Mailing Declaration,

¶16.


2
  Verita has re-mailed a total of one Postcard Notice to persons whose original mailings were
returned by the United States Postal Service (“USPS”) and for whom updated addresses were
provided to Verita by the USPS or were obtained through other means.
SUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED
NOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)
REQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF                                       -2-


       Case 1:23-cv-09476-KPF          Document 117         Filed 03/17/26      Page 4 of 4


       8.      Since the Initial Mailing Declaration was executed, and as of the date of this

declaration, Verita has not received any requests for exclusion.

       9.      Although the Notice Order (and the Notice) provides that Class Members who wish

to file objections must file them with the Court and copy them to relevant counsel (rather than to

Verita), I also note for the sake of completeness that as of the date of this declaration Verita has

not received any objections.

       I declare under penalty of perjury that the foregoing is true and correct and that this

declaration was executed this 13th day of March, 2026, at San Rafael, California.


                                                              ROSS D. MURRAY


SUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED
NOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)
REQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF                                      -3-