Common use of NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT Clause in Contracts

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. To: All current and former hourly non-exempt, hourly employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California from October 29, 2014 through <<PRELIM APPROVAL DATE>>, (these employees will be referred to as “Settlement Class Members”). The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxxxxx Xxxxxx v. Santa Xxxxxxx Farms, LLC, Santa Xxxxxxx County Superior Court Case No. 18CV05366 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx Farms, LLC’s (“SB Farms”) records show that you were employed at SB Farms as a non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation employee in California between October 29, 2014 and <<PRELIM APPROVAL DATE>> (the “Class Period”). The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against SB Farms seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for SB Farms at any time beginning October 29, 2014. Plaintiff Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms failed to pay Settlement Class members all minimum and overtime wages, failed to provide to Settlement Class members all required meal and rest periods, and failed to indemnify all necessary business expenditures. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms failed to provide accurate, itemized wage statements, engaged in unfair business practices, and seeks civil penalties under the Private Attorneys General Act of 2004. SB Farms denies that it has done anything wrong. SB Farms further denies that it owes Settlement Class members any wages, restitution, penalties, or other damages. Accordingly, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB Farms, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California law. However, to avoid additional expense, inconvenience, and interference with its business operations, SB Farms has concluded that it is in its best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the parties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB Farms, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB Farms, your decision about whether to participate in the Settlement will not affect your employment. California law strictly prohibits unlawful retaliation. SB Farms will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Members: XXXXXX LAW, APC Xxxxx X. Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>, the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California from October 29, 2014 through <<PRELIM APPROVAL DATE>>. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms as described below. SB Farms has agreed to pay $295,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Service Award. SB Farms’ share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. To: All current and former hourly non-exemptexempt employees of Defendant Mission Produce, hourly employees Inc. (“Mission Produce”) who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees Mission Produce in California at any time from October 29April 23, 2014 through 2016 to <<PRELIM APPROVAL DATEEND OF CLASS PERIOD>>, > (these employees will be referred to as “Settlement Class MembersPeriod”). The Los Angeles County Superior Court (“Court”) has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxxxxx that resolves two pending class action lawsuits against Mission Produce: Xxxxx Xxxx Xxxxxxx and Xxxxx Xxxxxx v. Santa Xxxxxxx FarmsMission Produce, LLCInc., Santa Xxxxxxx Los Angeles County Superior Court Case No. 18CV05366 20STCV15737 (the “LawsuitXxxxxxx Action”) and Xxxxxxx Manlalo Xxxxxxx x. Mission Produce, Inc., Ventura County Superior Court Case No. 56-2020-00542261-CU-OE-VTA (“Xxxxxxx Action”). The Xxxxxxx Action and Xxxxxxx Action are referred to together as the “Actions.” Because your rights may be affected by the Settlement, it is important that you read this notice Notice carefully. You may be entitled to money from this the Settlement. Defendant Santa Xxxxxxx Farms, LLCMission Produce’s (“SB Farms”) records show that you were employed at SB Farms by Mission Produce as a non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation exempt employee in California and performed work for Mission Produce at some point between October 29April 23, 2014 and 2016 through <<PRELIM APPROVAL DATEEND OF CLASS PERIOD>> (>, and are therefore part of the proposed “Class Period”). Settlement Class.” The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice Notice is to provide you with a brief description of the LawsuitActions, to inform you of the terms of the proposed Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxx Xxxxxx (“Plaintiff”) brought If final judgment is entered in this Lawsuit against SB Farms seeking case, it will be posted to assert claims on behalf of a class of current and former non-exempt employees who worked for SB Farms at any time beginning October 29, 2014. Plaintiff Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms failed to pay Settlement Class members all minimum and overtime wages, failed to provide to Settlement Class members all required meal and rest periods, and failed to indemnify all necessary business expenditures. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms failed to provide accurate, itemized wage statements, engaged in unfair business practices, and seeks civil penalties under the Private Attorneys General Act of 2004. SB Farms denies that it has done anything wrong. SB Farms further denies that it owes Settlement Class members any wages, restitution, penalties, or other damages. Accordingly, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsAdministrator’s website, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California law. However, to avoid additional expense, inconvenience, and interference with its business operations, SB Farms has concluded that it is in its best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the parties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB Farms, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB Farms, your decision about whether to participate in the Settlement will not affect your employment. California law strictly prohibits unlawful retaliation. SB Farms will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Members: XXXXXX LAW, APC Xxxxx X. Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvdxxx.xxxxxxxxxxxxxxxxxx.xxx., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>, the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California from October 29, 2014 through <<PRELIM APPROVAL DATE>>. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms as described below. SB Farms has agreed to pay $295,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Service Award. SB Farms’ share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. TK SERVICES, INC., a California corporation; and Does 1 through 100, Defendants. To: All current and former hourly non-exempt, hourly employees of Defendant TK Services, Inc. who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California at any time from October 29November 6, 2014 2013 through <<PRELIM APPROVAL DATE>>date of preliminary approval of the Settlement. Collectively, (these employees will be referred to as “Settlement Class Members”). members.” The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxxxxx Xxxxxx Xxxx Xxxxx v. Santa Xxxxxxx FarmsTK Services, LLCInc., Santa Xxxxxxx County Superior Court et al., Case No. 18CV05366 BC682512 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx Farms, LLCDefendant’s (“SB Farms”) records show that you were employed at SB Farms by TK Services, Inc. (“TK Services” or “Defendant”) as a non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation exempt employee in California between October 29November 6, 2014 2013, and <<PRELIM APPROVAL DATE>> (the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreement, the “Class Period”)” shall mean the time period of November 6, 2013 through the date the Court enters the order granting preliminary approval of this Settlement. The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxx Xxxxxx Xxxx Xxxxx (“Plaintiff”) brought this Lawsuit against SB Farms Defendant, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for SB Farms Defendant in California at any time beginning October 29November 6, 20142013. Plaintiff Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms TK Services failed to pay provide Settlement Class members all minimum and overtime minimum, overtime, and/or agreed-upon wages, failed to provide to Settlement Class members all legally required meal and rest periods, and failed to indemnify authorize and permit all necessary business expenditureslegally required rest periods. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, engaged in unfair business practices, practices and seeks is liable for civil penalties under the California Labor Code Private Attorneys Attorney General Act of 2004(“PAGA”). SB Farms TK Services denies that it has done anything wrong. SB Farms TK Services further denies that it owes Settlement Class members any wages, restitution, penalties, or other damages. Accordingly, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsTK Services, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California law. However, to avoid additional expense, inconvenience, and interference with its business operations, SB Farms TK Services has concluded that it is in its best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms TK Services provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the parties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB FarmsTK Services, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB FarmsTK Services, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibits prohibit unlawful retaliation. SB Farms TK Services will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Plaintiff/Settlement Class Attorneys for Defendant TK Services, Inc.: Members: XXXXXX LAW, APC Xxxxx X. Xxxxxx Xxxx X. Xxxxxxxxxxx xxxxxxx@xxxxxxxxx.xxx xxxx@xxxxxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx Xxxxxx X. Xxxxxx xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxxxxx.xxx Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Xx Xxxxxxx, Suite 1550 El SegundoXxxxxxxxxx 00000 00000 Xxxxxx Xxxx, California 90245 Xxxxx 000 Xxxxxxx Xxxxx, XX 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Xx Xxxxxxx, Suite 1550 El Segundo, California 90245 Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>[INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees TK Services in California at any time from October 29November 6, 2014 2013 through <<PRELIM APPROVAL DATE>>the date the Court enters the order granting preliminary approval of this Settlement. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms Defendant as described below. SB Farms Defendant has agreed to pay $295,000.00 1,750,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Representative’s Service Award. SB Farms’ Defendant’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from by Defendant separately from, and in addition to, the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. Defendants. To: All current and former hourly non-exemptexempt employees of Defendant Ready Roast Nut Company, hourly employees L.L.C. who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees at any time in California from October 29during the period of August 23, 2014 2016 through <<PRELIM APPROVAL DATE>>September 27, (2020. Collectively, these employees will be referred to as “Settlement Class Members”). .” The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in entitled Xxxxxx Xxxxxxxx Xxxxxx v. Santa Xxxxxxx FarmsReady Roast Nut Company, LLCL.L.C., Santa Xxxxxxx Madera County Superior Court Case No. 18CV05366 MCV084692 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx FarmsReady Roast Nut Company, LLC’s LLC (“SB FarmsDefendant”) records show that you were employed at SB Farms by Defendant as a non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation exempt employee in California at some time between October 29August 23, 2014 2016 and <<PRELIM APPROVAL DATE>> September 27, 2020 (the “Class Period”). The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice Notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxx Xxxxxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against SB Farms Defendant, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for SB Farms Defendant in California at any time beginning October 29on or after August 23, 20142016 through September 27, 2020. Plaintiff Xxxxxx Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his her attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms Defendant failed to provide meal periods, failed to authorize and permit rest periods, failed to provide accurate, itemized wage statements, failed to timely pay all wages upon termination, failed to pay Settlement Class members all minimum and overtime wages, failed to provide to Settlement Class members pay all required meal and rest periodsovertime wages, and failed to indemnify all reimburse necessary business expendituresexpenses, all in violation of California law. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms failed to provide accurate, itemized wage statements, Defendant engaged in unfair business practices, competition and seeks is liable for civil penalties under the California Labor Code Private Attorneys Attorney General Act of 2004(“PAGA”). SB Farms Defendant denies that it has done anything wrong. SB Farms Defendant further denies that it owes Settlement Class members any wages, restitution, penalties, or other damages. AccordinglyNo Court has made any determination as to the factual allegations in the Lawsuit. Rather, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsDefendant, which and it expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California lawDefendant violated any laws or whether Plaintiff or any other person is entitled to damages or other relief. However, to avoid additional expense, inconvenience, and interference with its their business operations, SB Farms Defendant has concluded that it is in its their best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms Defendant provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the partiesParties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB FarmsDefendant, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB Farms, your decision about whether to participate in the Settlement will not affect your employment. California law strictly prohibits unlawful retaliation. SB Farms will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Attorneys for Defendant Pacific Drayage Services, Members: XXXXXX LAW, APC LLC Xxxxx X. Xxxxxx Xxxxx X. Xxxxxxxx xxxxxxx@xxxxxxxxx.xxx xxxxx@xxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx 0000 X. Xxxxxxxx Xxxxxx, Xxxxx 000 xxxxxxx@xxxxxxxxx.xxx Fresno, California 93711 Xxxxx Xxxxx Tel: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx Fax: (000) 000-0000 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd.Xxxxxx Xxxxx, Suite 1550 Xxxxx 000 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>[INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees of Defendant Ready Roast Nut Company, L.L.C. who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees at any time in California from October 29during the period of August 23, 2014 2016 through <<PRELIM APPROVAL DATE>>September 27, 2020. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms Defendants as described below. SB Farms Defendant has agreed to pay $295,000.00 325,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including which includes payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Service Award. SB Farms’ share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the partiesParties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. To: All current and former hourly non-exempt, hourly exempt employees who worked for Defendant Santa Xxxxxxx FarmsTri-Star Window Coverings, LLC and were classified as harvesting employees and/or irrigation employees Inc. (“Defendant” or “Tri-Star”) in California California, who performed work that was, at least in part, compensated on a piece-rate basis, from October 29March 13, 2014 through <<PRELIM [PRELIMINARY APPROVAL DATE>>]. Collectively, (these employees will be referred to as “Settlement Class Members”). .” The Los Angeles Superior Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxxxxx Xxxxx Xxxxxxx and Xxxx Xxxxxx v. Santa Xxxxxxx FarmsTri-Star Window Coverings, LLCInc et al., Santa Xxxxxxx County Superior Court Case No. 18CV05366 BC697813 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx Farms, LLCTri-Star’s (“SB Farms”) records show that you were employed at SB Farms Tri- Star as a non-exemptexempt employee who performed work that was, hourly employee and were classified as at least in part, compensated on a harvesting employee and/or irrigation employee in California between October 29piece-rate basis, from March 13, 2014 and <<PRELIM through [PRELIMINARY APPROVAL DATE>> ] (the “Class Period”). The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxx Plaintiffs Xxxxx Xxxxxxx and Xxxx Xxxxxx (“PlaintiffPlaintiffs”) brought this Lawsuit against SB Farms Tri-Star, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for SB Farms Tri-Star in California at any time beginning October 29March 13, 2014. Plaintiff Xxxxxxxx Xxxxxx is Plaintiffs are known as the “Class RepresentativeRepresentatives,” and his their attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms Tri-Star failed to pay Settlement Class members all minimum overtime wages and overtime wages, failed to provide to reimburse Settlement Class members all required meal and rest periods, and failed to indemnify for all necessary business expendituresexpenses incurred during the Class Period. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms Tri-Star failed to provide accurate, itemized wage statements, statements and also engaged in unfair business practices, and seeks civil penalties under the Private Attorneys General Act of 2004. SB Farms Tri-Star denies that it has done anything wrong. SB Farms Tri-Star further denies that it owes Settlement Class members any wages, restitution, penalties, or other damages. Accordingly, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsTri- Star, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s Plaintiffs’ claims, but SB Farms believes that it has strong defenses that will show no violations of California law. However, to avoid additional expense, inconvenience, and interference with its business operations, SB Farms Tri-Star has concluded that it is in its best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms Tri-Star provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the parties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB FarmsTri-Star, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB FarmsTri-Star, your decision about whether to participate in the Settlement will not affect your employment. California law and Tri-Star’s policies strictly prohibits prohibit unlawful retaliation. SB Farms Tri-Star will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Attorneys for Defendant Tri-Star Window Coverings, Members: XXXXXX LAW, APC Inc. Xxxxx X. Xxxxxx Xxxxxx X. Xxxxx xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx 00000 Xxxxxx Xxxxxx, Xxxxx 0000 xxxxxxx@xxxxxxxxx.xxx Xxxxxxxx Hills, CA 91367 Xxxxx Xxxxx Tel: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Fax: (000) 000-0000 xxx.xxxxxxxxxx.xxx Xx Xxxxxxx, Suite 1550 El Segundo, California 90245 Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Xx Xxxxxxx, Suite 1550 El Segundo, California 90245 Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>[INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees who worked for Defendant Santa Xxxxxxx FarmsTri-Star in California, LLC and were classified as harvesting employees and/or irrigation employees performed work that was, at least in California from October 29part, compensated on a piece-rate basis, between March 13, 2014 through <<PRELIM and [PRELIMINARY APPROVAL DATE>>]. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms Tri-Star as described below. SB Farms Tri-Star has agreed to pay $295,000.00 100,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Representatives’ Service Award. SB Farms’ Tri-Star’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from by Tri-Star separately from, and in addition to, the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. To: All current and former hourly non-exempt, hourly employees of Defendant National Paving Company, Inc. (“Defendant” or “National Paving”) who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California from October 29at any time between March 19, 2014 through 2017 and <<PRELIM APPROVAL DATEDATE OF PRELIMINARY APPROVAL>>. Collectively, (these employees will be referred to as “Settlement Class Members”). .” The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxxxxx Xxxxxx Xxxxx Xxxxxx, as an individual and on behalf of all others similarly situated v. Santa Xxxxxxx FarmsNational Paving Company, LLCInc., Santa Xxxxxxx County Superior Court a California corporation; and DOES 1 through 100, inclusive, Case No. 18CV05366 CIVSB2108801 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx Farms, LLCNational Paving’s (“SB Farms”) records show that you were employed at SB Farms National Paving as a an hourly, non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation exempt employee in California between October 29March 19, 2014 2017 and <<PRELIM APPROVAL DATEDATE OF PRELIMINARY APPROVAL>> (the “Class Period”). The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxx Xxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against SB Farms National Paving, seeking to assert claims on behalf of a class of current and former non-exempt exempt, hourly employees who worked for SB Farms National Paving in California at any time beginning October 29between March 19, 20142017 and <<DATE OF PRELIMINARY APPROVAL>>. Plaintiff Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his attorneys, who also represent the interests of all Settlement Class membersMembers, are known as “Class Counsel.” The Lawsuit alleges that SB Farms National Paving failed to pay Settlement Class members Members all minimum and overtime wages, failed to provide to Settlement Class members Members all required meal and rest periods, failed to reimburse necessary business expenses, failed to provide Settlement Class Members with itemized wage statements in compliance with California law, and failed to indemnify pay all necessary business expenditures. wages due upon termination As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms failed to provide accurate, itemized wage statements, National Paving engaged in unfair business practices, practices and seeks is liable for civil penalties under the Labor Code Private Attorneys Attorney General Act of 2004Act. SB Farms National Paving denies that it has done anything wrong. SB Farms National Paving further denies that it owes Settlement Class members Members any wages, restitution, penalties, or other damages. Accordingly, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsNational Paving, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California law. However, to avoid additional expense, inconvenience, and interference with its business operations, SB Farms National Paving has concluded that it is in its best interests and the interests of Settlement Class members Members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms National Paving provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the parties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB FarmsNational Paving, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB FarmsNational Paving, your decision about whether to participate in the Settlement will not affect your employment. California law and National Paving’s policies strictly prohibits prohibit unlawful retaliation. SB Farms National Paving will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member Member because of the Settlement Class memberMember’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Attorneys for National Paving company, Inc. Members: XXXXXXX XXXXXXXX & XXXXXX LAWLLP XXXXXX XXX, APC Xxxxx X. Xxxxxx Xxxxx X. Xxxxxx xxxxxxx@xxxxxx.xxx xxxxxxx@xxxxxxxxx.xxx 00000 Xxxxxxxxx Xxxx., Xxxxx 000 Xxxxxxxxx Xxxxxx Xxxxxxxx, Xxxxxxxxxx 00000 xxxxxxx@xxxxxxxxx.xxx Tel: (000) 000-0000 Xxxxx Xxxxx Fax: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx xxx.xxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Xx Xxxxxxx, Suite 1550 El Segundo, California 90245 Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 X. Xxxxxxxxx Blvd.Xx Xxxxxxx, Suite 1550 El Segundo, California 90245 Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>[INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt exempt, hourly employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees National Paving in California from October 29at any time between March 19, 2014 through 2017 and <<PRELIM APPROVAL DATEDATE OF PRELIMINARY APPROVAL>>. Settlement Class members Members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms National Paving as described below. SB Farms National Paving has agreed to pay $295,000.00 150,000 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including which includes payments to Settlement Class membersMembers, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”)of PAGA civil penalties, settlement administration costs, and the Class Representative Representative’s Service Award. SB Farms’ National Paving’s share of payroll taxes associated with any wage payments to Settlement Class members Members shall be paid from by National Paving separately from, and in addition to, the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties:

NOTICE OF PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT. To: All current and former hourly non-exempt, hourly exempt employees who have worked for Defendant Santa Defendants SmileDirectClub, LLC, and Xxxxxxx FarmsXxxxxxxx, LLC and were classified as harvesting employees and/or irrigation employees D.M.D., Professional Corporation (“Defendants”) in California from October 29during the time period of November 8, 2014 2017 through <<PRELIM APPROVAL DATE>>[date court grants preliminary approval]. Collectively, (these employees will be referred to as “Settlement Class Members”). .” The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in entitled Xxxxxxxxx Xxxxxxxx Xxxxxx v. Santa Xxxxxxx FarmsSmileDirectClub, LLC, Santa and Xxxxxxx County Xxxxxxxx, D.M.D., Professional Corporation, Los Angeles Superior Court Case No. 18CV05366 20STCV03799 (the “Lawsuit”). Because your rights may be affected by the Settlement, it is important that you read this notice carefully. You may be entitled to money from this Settlement. Defendant Santa Xxxxxxx Farms, LLC’s (“SB Farms”) Defendants’ records show that you were employed at SB Farms Defendants as a an hourly, non-exempt, hourly employee and were classified as a harvesting employee and/or irrigation exempt employee in California between October 29November 8, 2014 and <<PRELIM APPROVAL DATE>> 2017 through [date court grants preliminary approval] (the “Class Period”). The Court ordered that this Notice be sent to you because you may be entitled to money under the Settlement and because the Settlement affects your legal rights. The purpose of this notice Notice is to provide you with a brief description of the Lawsuit, to inform you of the terms of the Settlement, to describe your rights in connection with the Settlement, and to explain what steps you may take to participate in, object to, or exclude yourself from the Settlement. If you do not exclude yourself from the Settlement and the Court finally approves the Settlement, you will be bound by the terms of the Settlement and any final judgment. Plaintiff Xxxxxxxxx Xxxxxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against SB Farms Defendants, seeking to assert claims on behalf of a class of current and former hourly, non-exempt employees who worked for SB Farms Defendants, in California at any time beginning October 29on or after November 8, 20142017. Plaintiff Xxxxxxxxx Xxxxxxxx Xxxxxx is known as the “Class Representative,” and his attorneys, who also represent the interests of all Settlement Class members, are known as “Class Counsel.” The Lawsuit alleges that SB Farms Defendants failed to pay Settlement Class members all minimum and overtime wageswages owed, failed to provide to Settlement Class members all required meal and rest periods, and failed to indemnify provide Settlement Class members with itemized wage statements in compliance with California law. The Lawsuit also alleges that Defendants failed to timely pay all necessary business expenditureswages owed to Settlement Class members upon their separation of employment from Defendants. As a result of the foregoing alleged violations, Plaintiff also alleges that SB Farms failed to provide accurate, itemized wage statements, Defendants engaged in unfair business practices, practices and seeks are liable for civil penalties under the Labor Code Private Attorneys Attorney General Act of 2004Act. SB Farms denies Defendants deny that it has they have done anything wrong. SB Farms Defendants further denies deny that it owes they owe Settlement Class members any wages, restitution, penalties, or other damages. AccordinglyNo Court has made any determination as to the factual allegations in the Lawsuit. Rather, the Settlement constitutes a compromise of disputed claims and should not be construed as an admission of liability on the part of SB FarmsDefendants, which and they expressly denies deny all liability. Defendant SmileDirectClub, LLC denies it employed any Settlement Class members in the state of California during the Class Period. The Court has not ruled on the merits of Plaintiff’s claims, but SB Farms believes that it has strong defenses that will show no violations of California lawDefendants violated any laws or whether Plaintiff or any other person is entitled to damages or other relief. However, to avoid additional expense, inconvenience, and interference with its their business operations, SB Farms has Defendants have concluded that it is in its their best interests and the interests of Settlement Class members to settle the Lawsuit on the terms summarized in this Notice. After SB Farms Defendants provided relevant information to Class Counsel, the Settlement was reached after mediation and arm’s-length negotiations between the partiesParties. The Class Representative and Class Counsel support the Settlement. Among the reasons for support are the defenses to liability potentially available to SB FarmsDefendants, the risk of denial of class certification, the inherent risks of trial on the merits, and the delays and uncertainties associated with litigation. If you are still employed by SB Farms, your decision about whether to participate in the Settlement will not affect your employment. California law strictly prohibits unlawful retaliation. SB Farms will not take any adverse employment action against or otherwise target, retaliate, or discriminate against any Settlement Class member because of the Settlement Class member’s decision to either participate or not participate in the Settlement. Attorneys for the Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Members: XXXXXX LAW, APC Xxxxx X. Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxx xxxxxxx@xxxxxxxxx.xxx Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx Attorneys for the Plaintiff Xxxxxxxx Xxxxxx/ Settlement Class Members: XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 000 X. Xxxxxxxxx Blvd., Suite 1550 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx Attorneys for Defendant Santa Xxxxxxx Farms, LLC XXXXXX & HENZELL L.L.P. Xxxxxx Xxxxxxxx XXxxxxxxx@xxxxxxxxx.xxx Xxxxxxxxx Xxxxxxx xxxxxxxx@XxxxxxXxx.xxx 000 Xxxx Xxxxxxxx Xxxxxx Post Xxxxxx Xxxxxx 000 Xxxxx Xxxxxxx, Xxxxxxxxxx 00000-0000 On <<PRELIM APPROVAL DATE>>, the Court preliminarily certified a class, for settlement purposes only, of all current and former hourly non-exempt employees who worked for Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California from October 29, 2014 through <<PRELIM APPROVAL DATE>>. Settlement Class members who do not opt out of the Settlement pursuant to the procedures set forth in this Notice will be bound by the Settlement and will release their claims against SB Farms as described below. SB Farms has agreed to pay $295,000.00 (the “Gross Settlement Amount”) to fully resolve all claims in the Lawsuit, including payments to Settlement Class members, attorneys’ fees and expenses, payment to the Labor Workforce Development Agency (“LWDA”), settlement administration costs, and the Class Representative Service Award. SB Farms’ share of payroll taxes associated with any wage payments to Settlement Class members shall be paid from the Gross Settlement Amount. The following deductions from the Gross Settlement Amount will be requested by the parties: