Plaintiff Christina Romero (Plaintiff) filed a complaint in this Action in San Bernardino Superior Court on February 17, 2023 and an amended complaint on September 6, 2024. Plaintiff alleges claims for failure to pay wages, failure to provide meal periods and rest breaks, failure to pay all wages owed, failure to pay sick time, failure to reimburse business related expenses, failure to provide accurate itemized wage statements, failure to maintain records, failure to timely pay final wages, failure to pay wages without discount due to fees allegedly incurred due to the use of pay cards, statutory unfair competition, and civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA).
The proposed Settlement is not an admission of liability by Defendant. Throughout this case, Defendant has denied any liability or wrongdoing, or that any compensable injury arose out of any of the matters alleged in the Action. Defendant contends that it has complied with all California and federal laws regarding those matters.
Class Counsel believes that the proposed Settlement is in the best interests of the Class Members. Further proceedings would be very expensive and take a long time. Moreover, no one can predict the precise outcome of the disputed issues in this case. Therefore, Class Counsel believes that the proposed Settlement is fair, reasonable, and adequate for the Class Members.
The Court has preliminarily approved the proposed Settlement and approved the Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read the Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys. The Court will also decide whether to enter a judgment that requires Defendant to make payments under the Settlement and requires Class Members and PAGA Group Members to give up their rights to assert certain claims against Defendant
SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT | |
You Do Not Have to Do Anything to Participate in the Settlement | If you do nothing, you will be a Settlement Class Member, eligible for an individual Class Settlement Award and individual PAGA Settlement Award (if any). In exchange, you will give up your right to assert the wage claims against Defendant that are covered by this Settlement (Released Claims). |
You Can Opt-out of the Class Settlement but not the PAGA Settlement The Opt-out Deadline is January 25, 2025 | If you do not want to fully participate in the proposed Settlement, you can opt-out of the Class Settlement by sending the Settlement Administrator a written Request for Exclusion. Once excluded, you will be no longer eligible for an individual Class Settlement Award. You also cannot object to any portion of the proposed Settlement. See FAQ 6. You cannot opt-out of the PAGA portion of the proposed Settlement. |
Settlement Class Members Can Object to the Class Settlement but not the PAGA Settlement Written Objections Must be Submitted by January 25, 2025 | All Class Members who do not opt-out (Settlement Class Members) can object to any aspect of the proposed Settlement. The Court’s decision whether to finally approve the Settlement will include a determination of how much will be paid to Class Counsel and Plaintiff who pursued the Action on behalf of the Class. You are not personally responsible for any payments to Class Counsel or Plaintiff, but every dollar paid to Class Counsel and Plaintiff reduces the overall amount paid to Settlement Class Members. You can object to the amounts requested by Class Counsel or Plaintiff if you think they are unreasonable. See FAQ 7. |
You Can Participate in the March 13, 2025 Final Approval Hearing | The Court’s Final Approval Hearing is scheduled to take place on March 13, 2025. You do not have to attend but you do have the right to appear (or hire an attorney to appear on your behalf at your own cost), in person, by telephone or by using the Court’s virtual appearance platform. Settlement Class Members can verbally object to the Settlement at the Final Approval Hearing. See FAQ 8. |
You Can Challenge the Calculation of Your Workweeks Written Challenges Must be Submitted by January 25, 2025 | The amount of your individual Class Settlement Award depend on how many workweeks you worked at least one day during the Class Period. The number Class Work Weeks you worked according to Defendant’s records is stated on the first page of the Notice and in the accompanying Notice of Eligible Work Weeks Form A. If you disagree, you must challenge it by January 25, 2025. See the Notice of Eligible Work Weeks Form A. |
Upcoming Important Dates
Opt Out Deadline
1/25/2025
Objection Deadline
1/25/2025
Dispute Deadline
1/25/2025
Final Approval Hearing
3/13/2025