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

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 non-exempt, hourly employees of Defendant TK Services, Inc. who worked for Defendant in California at any time from November 6, 2013 through date of preliminary approval of the Settlement. Collectively, these employees will be referred to as “Settlement Class members.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxx Xxxxx v. TK Services, Inc., et al., Case No. 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’s records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) as a non-exempt employee in California between November 6, 2013, and 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. What is this case about? Plaintiff Xxxx Xxxxx (“Plaintiff”) brought this Lawsuit against Defendant, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant in California at any time beginning November 6, 2013. Plaintiff 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 TK Services failed to provide Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periods, and failed to authorize and permit all legally required rest periods. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, engaged in unfair business practices and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”). TK Services denies that it has done anything wrong. 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 TK Services, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims. However, to avoid additional expense, inconvenience, and interference with its business operations, 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 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 TK 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 TK Services, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibit unlawful retaliation. 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. Who are the Attorneys? Attorneys for the Plaintiff/Settlement Class Attorneys for Defendant TK Services, Inc.: Members: XXXXXX LAW, APC COPENBARGER & ASSOCIATES 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 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, 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 XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees who worked for TK Services in California at any time from November 6, 2013 through 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 Defendant as described below. Defendant has agreed to pay $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’s Service Award. Defendant’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid 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. TK SERVICES, INC., a California corporation; and Does 1 through 100, Defendants. To: All current and former non-exempt, hourly exempt employees of who for Defendant TK ServicesTri-Star Window Coverings, Inc. (“Defendant” or “Tri-Star”) in California, who worked for Defendant performed work that was, at least in California at any time part, compensated on a piece-rate basis, from November 6March 13, 2013 2014 through date of preliminary approval of the Settlement[PRELIMINARY APPROVAL DATE]. Collectively, these employees will be referred to as “Settlement Class membersMembers.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Los Angeles Superior Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxx Xxxxxxx and Xxxx Xxxxx Xxxxxx v. TK ServicesTri-Star Window Coverings, Inc., Inc et al., Case No. BC682512 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. DefendantTri-Star’s records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) at Tri- Star as a non-exempt employee who performed work that was, at least in California between November 6part, 2013compensated on a piece-rate basis, and the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreementfrom March 13, 2014 through [PRELIMINARY APPROVAL DATE] (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. What is this case about? Plaintiff Plaintiffs Xxxxx Xxxxxxx and Xxxx Xxxxx Xxxxxx (“PlaintiffPlaintiffs”) brought this Lawsuit against DefendantTri-Star, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant Tri-Star in California at any time beginning November 6March 13, 20132014. Plaintiff 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 TK Services Tri-Star failed to provide pay Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periods, overtime wages and failed to authorize and permit reimburse Settlement Class members for all legally required rest periodsnecessary business expenses incurred during the Class Period. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services Tri-Star failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, statements and also engaged in unfair business practices and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”)practices. TK Services Tri-Star denies that it has done anything wrong. TK Services 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 TK ServicesTri- Star, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s Plaintiffs’ claims. However, to avoid additional expense, inconvenience, and interference with its business operations, TK Services 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 TK Services 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 TK ServicesTri-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 TK ServicesTri-Star, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ Tri-Star’s policies strictly prohibit unlawful retaliation. TK Services 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. Who are the Attorneys? Attorneys for the Plaintiff/Plaintiff / Settlement Class Attorneys for Defendant TK ServicesTri-Star Window Coverings, Inc.: Members: Inc. XXXXXX LAW, APC COPENBARGER & ASSOCIATES X’XXXXX XXXXX Xxxxx X. Xxxxxx Xxxx Xxxxxx X. Xxxxxxxxxxx Xxxxx xxxxxxx@xxxxxxxxx.xxx xxxx@xxxxxxxxxxxxxx.xxx xxxxxx@xxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx 00000 Xxxxxx X. Xxxxxx Xxxxxx, Xxxxx 0000 xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxxxxx.xxx Xxxxxxxx Hills, CA 91367 Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, Xxxxx 000 Xxxxxxx Xxxxx, XX 00000 Tel: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Fax: (000) 000-0000 xxx.xxxxxxxxxx.xxx Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees who worked for TK Services Tri-Star in California California, and performed work that was, at any time from November 6least in part, 2013 through the date the Court enters the order granting preliminary approval of this Settlementcompensated on a piece-rate basis, between March 13, 2014 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 Defendant Tri-Star as described below. Defendant Tri-Star has agreed to pay $1,750,000.00 100,000.00 (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’s Representatives’ Service Award. DefendantTri-Star’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid by Defendant 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. TK SERVICES, INC., a California corporation; and Does 1 through 100, Defendants. To: All current and former non-exempt, hourly employees of Defendant TK ServicesNational Paving Company, Inc. (“Defendant” or “National Paving”) who worked for Defendant in California at any time from November 6between March 19, 2013 through date of preliminary approval of the Settlement2017 and <<DATE OF PRELIMINARY APPROVAL>>. Collectively, these employees will be referred to as “Settlement Class membersMembers.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxx Xxxxx Xxxxxx, as an individual and on behalf of all others similarly situated v. TK ServicesNational Paving Company, Inc., et al.a California corporation; and DOES 1 through 100, inclusive, Case No. BC682512 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. DefendantNational Paving’s records show that you were employed by TK Servicesat National Paving as an hourly, Inc. (“TK Services” or “Defendant”) as a non-exempt employee in California between November 6March 19, 2013, 2017 and the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreement, <<DATE OF PRELIMINARY APPROVAL>> (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. What is this case about? Plaintiff Xxxx Xxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against DefendantNational Paving, seeking to assert claims on behalf of a class of current and former non-exempt exempt, hourly employees who worked for Defendant National Paving in California at any time beginning November 6between March 19, 20132017 and <<DATE OF PRELIMINARY APPROVAL>>. Plaintiff 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 TK Services National Paving failed to pay Settlement Class Members all minimum and overtime wages, failed to provide to Settlement Class Members all required meal and rest periods, failed to reimburse necessary business expenses, failed to provide Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periodsMembers with itemized wage statements in compliance with California law, and failed to authorize and permit pay all legally required rest periods. wages due upon termination As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, National Paving engaged in unfair business practices and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”)Act. TK Services National Paving denies that it has done anything wrong. TK Services 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 TK ServicesNational Paving, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims. However, to avoid additional expense, inconvenience, and interference with its business operations, TK Services 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 TK Services 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 TK ServicesNational 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 TK ServicesNational Paving, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ National Paving’s policies strictly prohibit unlawful retaliation. TK Services 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. Who are the Attorneys? Attorneys for the Plaintiff/Plaintiff / Settlement Class Attorneys for Defendant TK ServicesNational Paving company, Inc.: Inc. Members: XXXXXXX XXXXXXXX & XXXXXX LAWLLP XXXXXX XXX, APC COPENBARGER & ASSOCIATES Xxxxx X. Xxxxxx Xxxx Xxxxx X. Xxxxxxxxxxx Xxxxxx xxxxxxx@xxxxxx.xxx xxxxxxx@xxxxxxxxx.xxx xxxx@xxxxxxxxxxxxxx.xxx 00000 Xxxxxxxxx Xxxx., Xxxxx 000 Xxxxxxxxx Xxxxxx Xxxxxx X. Xxxxxx Xxxxxxxx, Xxxxxxxxxx 00000 xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxxxxx.xxx Tel: (000) 000-0000 Xxxxx Xxxxx Fax: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx xxx.xxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, 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 XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt exempt, hourly employees who worked for TK Services National Paving in California at any time from November 6between March 19, 2013 through the date the Court enters the order granting preliminary approval of this Settlement2017 and <<DATE 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 Defendant National Paving as described below. Defendant National Paving has agreed to pay $1,750,000.00 150,000 (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’s Service Award. DefendantNational Paving’s share of payroll taxes associated with any wage payments to Settlement Class members Members shall be paid by Defendant 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. TK SERVICES, INC., a California corporation; and Does 1 through 100, Defendants. To: All current and former non-exempt, hourly exempt employees of Defendant TK ServicesReady Roast Nut Company, Inc. L.L.C. who worked for Defendant in California at any time from November 6in California during the period of August 23, 2013 2016 through date of preliminary approval of the SettlementSeptember 27, 2020. Collectively, these employees will be referred to as “Settlement Class membersMembers.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxx Xxxxx entitled Xxxxxx Xxxxxxxx v. TK ServicesReady Roast Nut Company, Inc.L.L.C., et al., Madera County Superior Court Case No. BC682512 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 Ready Roast Nut Company, LLC (“Defendant’s ”) records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) Defendant as a non-exempt employee in California at some time between November 6August 23, 20132016 and September 27, and the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreement, 2020 (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 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. What is this case about? Plaintiff Xxxx Xxxxx Xxxxxx Xxxxxxxx (“Plaintiff”) brought this Lawsuit against Defendant, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant in California at any time beginning November 6on or after August 23, 20132016 through September 27, 2020. Plaintiff Xxxxxx Xxxxxxxx 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 TK Services Defendant failed to provide Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periods, and failed to authorize and permit all legally required rest periods, failed to provide accurate, itemized wage statements, failed to timely pay all wages upon termination, failed to pay all minimum wages, failed to pay all overtime wages, and failed to reimburse necessary business expenses, all in violation of California law. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, Defendant engaged in unfair business practices competition and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”). TK Services Defendant denies that it has done anything wrong. TK Services 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 TK ServicesDefendant, which and it expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claimsthat Defendant 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, TK Services 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 TK Services 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 TK ServicesDefendant, 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 TK Services, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibit unlawful retaliation. 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. Who are the Attorneys? Attorneys for the Plaintiff/Plaintiff / Settlement Class Attorneys for Defendant TK Pacific Drayage Services, Inc.: Members: LLC XXXXXX LAWXXX, APC COPENBARGER & ASSOCIATES XXXXXXXX LAW GROUP Xxxxx X. Xxxxxx Xxxx Xxxxx X. Xxxxxxxxxxx Xxxxxxxx xxxxxxx@xxxxxxxxx.xxx xxxx@xxxxxxxxxxxxxx.xxx xxxxx@xxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx Xxxxxx 0000 X. Xxxxxx xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxxxxx.xxx Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx XxxxxXxxxxxxx Xxxxxx, Xxxxx 000 Xx Xxxxxxxxxxxxxx@xxxxxxxxx.xxx Fresno, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, California 93711 Xxxxx 000 Xxxxxxx Xxxxx, XX 00000 Xxxxx Tel: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx Fax: (000) 000-0000 0000 Xxxxxx Xxxxx, Xxxxx 000 El Segundo, California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 000 Xxxxxx Xxxxx, Xxxxx 000 Xx XxxxxxxEl Segundo, Xxxxxxxxxx 00000 California 90245 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees of Defendant Ready Roast Nut Company, L.L.C. who worked for TK Services in California Defendant at any time from November 6in California during the period of August 23, 2013 2016 through the date the Court enters the order granting preliminary approval of this SettlementSeptember 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 Defendant Defendants as described below. Defendant has agreed to pay $1,750,000.00 325,000.00 (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’s Representative Service Award. Defendant’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid 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 partiesParties:

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 non-exempt, hourly exempt employees of Defendant TK Services, Inc. who have worked for Defendant Defendants SmileDirectClub, LLC, and Xxxxxxx Xxxxxxxx, D.M.D., Professional Corporation (“Defendants”) in California at any during the time from period of November 68, 2013 2017 through [date of court grants preliminary approval of the Settlementapproval]. Collectively, these employees will be referred to as “Settlement Class membersMembers.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxx Xxxxx entitled Xxxxxxxxx Xxxxxxxx v. TK ServicesSmileDirectClub, Inc.LLC, et al.and Xxxxxxx Xxxxxxxx, D.M.D., Professional Corporation, Los Angeles Superior Court Case No. BC682512 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’s Defendants’ records show that you were employed by TK Servicesat Defendants as an hourly, Inc. (“TK Services” or “Defendant”) as a non-exempt employee in California between November 68, 2013, and the 2017 through [date the Court enters the order granting court grants preliminary approval of this Settlement. For purposes of this Settlement Agreement, approval] (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 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. What is this case about? Plaintiff Xxxx Xxxxx Xxxxxxxxx Xxxxxxxx (“Plaintiff”) brought this Lawsuit against DefendantDefendants, seeking to assert claims on behalf of a class of current and former hourly, non-exempt employees who worked for Defendant Defendants, in California at any time beginning on or after November 68, 20132017. Plaintiff Xxxxxxxxx Xxxxxxxx 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 TK Services Defendants failed to pay all minimum and overtime wages owed, failed to provide to Settlement Class members all required meal and rest periods, and failed to provide Settlement Class members all minimum, overtime, and/or agreed-upon wages, with itemized wage statements in compliance with California law. The Lawsuit also alleges that Defendants failed to provide timely pay all legally required meal periods, and failed wages owed to authorize and permit all legally required rest periodsSettlement Class members upon their separation of employment from Defendants. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, Defendants engaged in unfair business practices and is are liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”)Act. TK Services denies Defendants deny that it has they have done anything wrong. TK Services 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 TK ServicesDefendants, 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 claimsthat Defendants 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, TK Services 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 TK Services 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 TK ServicesDefendants, 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 TK Services, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibit unlawful retaliation. 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. Who are the Attorneys? Attorneys for the Plaintiff/Settlement Class Attorneys for Defendant TK Services, Inc.: Members: XXXXXX LAW, APC COPENBARGER & ASSOCIATES 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 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, 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 XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees who worked for TK Services in California at any time from November 6, 2013 through 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 Defendant as described below. Defendant has agreed to pay $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’s Service Award. Defendant’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid 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. 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 November 6October 29, 2013 2014 through date of preliminary approval of the Settlement. Collectively<<PRELIM APPROVAL DATE>>, (these employees will be referred to as “Settlement Class members.” Members”). PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxx Xxxxx Xxxxxxxx Xxxxxx v. TK ServicesSanta Xxxxxxx Farms, Inc.LLC, et al., Santa Xxxxxxx County Superior Court Case No. BC682512 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. DefendantDefendant Santa Xxxxxxx Farms, LLC’s (“SB Farms”) records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) at SB Farms as a non-exempt exempt, hourly employee and were classified as a harvesting employee and/or irrigation employee in California between November 6October 29, 2013, 2014 and the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreement, <<PRELIM APPROVAL DATE>> (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. What is this case about? Plaintiff Xxxx Xxxxx Xxxxxxxx Xxxxxx (“Plaintiff”) brought this Lawsuit against Defendant, SB Farms seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant in California SB Farms at any time beginning November 6October 29, 20132014. 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 TK Services SB Farms failed to provide pay Settlement Class members all minimum, overtime, and/or agreed-upon minimum and overtime wages, failed to provide to Settlement Class members all legally required meal and rest periods, and failed to authorize and permit indemnify all legally required rest periodsnecessary business expenditures. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services SB Farms failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, engaged in unfair business practices practices, and is liable for seeks civil penalties under the California Labor Code Private Attorney Attorneys General Act (“PAGA”)of 2004. TK Services SB Farms denies that it has done anything wrong. TK Services 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 TK ServicesSB 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, TK Services 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 TK Services 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 TK ServicesSB 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 TK ServicesSB Farms, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibit prohibits unlawful retaliation. TK Services 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. Who are the Attorneys? Attorneys for the Plaintiff/Plaintiff Xxxxxxxx Xxxxxx / Settlement Class Attorneys for Defendant TK Services, Inc.: Members: XXXXXX LAW, APC COPENBARGER & ASSOCIATES 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 Xxxxx000 X. Xxxxxxxxx Blvd., Xxxxx 000 Xx XxxxxxxSuite 1550 El Segundo, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, Xxxxx 000 Xxxxxxx Xxxxx, XX 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 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 0000 Xxxxxx Xxxxx000 X. Xxxxxxxxx Blvd., Xxxxx 000 Xx XxxxxxxSuite 1550 El Segundo, Xxxxxxxxxx 00000 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 What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL]<<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 TK Services Defendant Santa Xxxxxxx Farms, LLC and were classified as harvesting employees and/or irrigation employees in California at any time from November 6October 29, 2013 2014 through the date the Court enters the order granting preliminary approval of this Settlement<<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 Defendant SB Farms as described below. Defendant SB Farms has agreed to pay $1,750,000.00 295,000.00 (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’s Representative Service Award. Defendant’s SB Farms’ share of payroll taxes associated with any wage payments to Settlement Class members shall be paid by Defendant separately from, and in addition to, 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 non-exempt, hourly exempt employees of Defendant TK ServicesMission Produce, Inc. (“Mission Produce”) who worked for Defendant Mission Produce in California at any time from November 6April 23, 2013 through date of preliminary approval of the Settlement2016 to <<END OF CLASS PERIOD>> (“Class Period”). Collectively, these employees will be referred to as “Settlement Class members.” PLEASE READ THIS NOTICE CAREFULLY CAREFULLY. YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT NOT. Why should you read this noticeNotice? The Los Angeles County Superior Court (“Court”) has granted preliminary approval of a proposed class action settlement (the “Settlement”) in that resolves two pending class action lawsuits against Mission Produce: Xxxxx Xxxx Xxxxxxx and Xxxxx Xxxxxx v. TK ServicesMission Produce, Inc., et al., Los Angeles County Superior Court Case No. BC682512 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. DefendantMission Produce’s records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) Mission Produce as a non-exempt employee in California and performed work for Mission Produce at some point between November 6April 23, 20132016 through <<END OF CLASS PERIOD>>, and are therefore part of the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this proposed “Settlement Agreement, the “Class PeriodClass.” 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 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. If final judgment is entered in this case, it will be posted to the Settlement Administrator’s website, xxx.xxxxxxxxxxxxxxxxxx.xxx. What is this case about? Plaintiff Xxxx Xxxxx (“Plaintiff”) brought this Lawsuit against Defendant, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant in California at any time beginning November 6, 2013. Plaintiff 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 TK Services failed to provide Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periods, and failed to authorize and permit all legally required rest periods. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, engaged in unfair business practices and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”). TK Services denies that it has done anything wrong. 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 TK Services, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s claims. However, to avoid additional expense, inconvenience, and interference with its business operations, 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 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 TK 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 TK Services, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ policies strictly prohibit unlawful retaliation. 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. Who are the Attorneys? Attorneys for the Plaintiff/Settlement Class Attorneys for Defendant TK Services, Inc.: Members: XXXXXX LAW, APC COPENBARGER & ASSOCIATES 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 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, 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 XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees who worked for TK Services in California at any time from November 6, 2013 through 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 Defendant as described below. Defendant has agreed to pay $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’s Service Award. Defendant’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid 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. TK SERVICES, INC., a California corporation; and Does 1 through 100, Defendants. To: All current and former non-exempt, hourly exempt employees of who for Defendant TK ServicesTri-Star Window Coverings, Inc. (“Defendant” or “Tri-Star”) in California, who worked for Defendant performed work that was, at least in California at any time part, compensated on a piece-rate basis, from November 6March 13, 2013 2014 through date of preliminary approval of the Settlement[PRELIMINARY APPROVAL DATE]. Collectively, these employees will be referred to as “Settlement Class membersMembers.” PLEASE READ THIS NOTICE CAREFULLY YOUR LEGAL RIGHTS MAY BE AFFECTED WHETHER YOU ACT OR NOT Why should you read this notice? The Los Angeles Superior Court has granted preliminary approval of a proposed class action settlement (the “Settlement”) in Xxxxx Xxxxxxx and Xxxx Xxxxx Xxxxxx v. TK ServicesTri-Star Window Coverings, Inc., Inc et al., Case No. BC682512 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. DefendantTri-Star’s records show that you were employed by TK Services, Inc. (“TK Services” or “Defendant”) at Tri- Star as a non-exempt employee who performed work that was, at least in California between November 6part, 2013compensated on a piece-rate basis, and the date the Court enters the order granting preliminary approval of this Settlement. For purposes of this Settlement Agreementfrom March 13, 2014 through [PRELIMINARY APPROVAL DATE] (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. What is this case about? Plaintiff Plaintiffs Xxxxx Xxxxxxx and Xxxx Xxxxx Xxxxxx (“PlaintiffPlaintiffs”) brought this Lawsuit against DefendantTri-Star, seeking to assert claims on behalf of a class of current and former non-exempt employees who worked for Defendant Tri-Star in California at any time beginning November 6March 13, 20132014. Plaintiff 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 TK Services Tri-Star failed to provide pay Settlement Class members all minimum, overtime, and/or agreed-upon wages, failed to provide all legally required meal periods, overtime wages and failed to authorize and permit reimburse Settlement Class members for all legally required rest periodsnecessary business expenses incurred during the Class Period. As a result of the foregoing alleged violations, Plaintiff also alleges that TK Services Tri-Star failed to provide accurate, itemized wage statements, failed to pay all wages upon termination of employment, statements and also engaged in unfair business practices and is liable for civil penalties under the California Labor Code Private Attorney General Act (“PAGA”)practices. TK Services Tri-Star denies that it has done anything wrong. TK Services 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 TK ServicesTri- Star, which expressly denies all liability. The Court has not ruled on the merits of Plaintiff’s Plaintiffs’ claims. However, to avoid additional expense, inconvenience, and interference with its business operations, TK Services 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 TK Services 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 TK ServicesTri-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 TK ServicesTri-Star, your decision about whether to participate in the Settlement will not affect your employment. California law and TK Services’ Tri-Star’s policies strictly prohibit unlawful retaliation. TK Services 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. Who are the Attorneys? Attorneys for the Plaintiff/Plaintiff / Settlement Class Attorneys for Defendant TK ServicesTri-Star Window Coverings, Inc.: Members: Inc. XXXXXX LAW, APC COPENBARGER & ASSOCIATES O’XXXXX XXXXX Xxxxx X. Xxxxxx Xxxx Xxxxxx X. Xxxxxxxxxxx Xxxxx xxxxxxx@xxxxxxxxx.xxx xxxx@xxxxxxxxxxxxxx.xxx xxxxxx@xxxxxxxxxxx.xxx Xxxxxxxxx Xxxxxx 00000 Xxxxxx X. Xxxxxx Xxxxxx, Xxxxx 0000 xxxxxxx@xxxxxxxxx.xxx xxxxxx@xxxxxxxxxxxxxx.xxx Xxxxxxxx Hills, CA 91367 Xxxxx Xxxxx xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 00000 Xxxxxx Xxxx, Xxxxx 000 Xxxxxxx Xxxxx, XX 00000 Tel: (000) 000-0000 xxxxxx@xxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Fax: (000) 000-0000 xxx.xxxxxxxxxx.xxx Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxx.xxx XXXXXX LAW GROUP, APC Xxxx X. Xxxxxx xxxxxxx@xxxxxxxxxxxxxx.xxx 0000 Xxxxxx Xxxxx, Xxxxx 000 Xx Xxxxxxx, Xxxxxxxxxx 00000 Tel: (000) 000-0000 Fax: (000) 000-0000 xxx.xxxxxxxxxxxxxx.xxx What are the terms of the Settlement? On [INSERT DATE OF PRELIMINARY APPROVAL], the Court preliminarily certified a class, for settlement purposes only, of all current and former non-exempt employees who worked for TK Services Tri-Star in California California, and performed work that was, at any time from November 6least in part, 2013 through the date the Court enters the order granting preliminary approval of this Settlementcompensated on a piece-rate basis, between March 13, 2014 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 Defendant Tri-Star as described below. Defendant Tri-Star has agreed to pay $1,750,000.00 100,000.00 (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’s Representatives’ Service Award. DefendantTri-Star’s share of payroll taxes associated with any wage payments to Settlement Class members shall be paid by Defendant 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: