Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June , 2023 By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration and Finance Dated: 6/30/2023 Xxxxx Xxxxxxx Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys for Plaintiff You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University ("MSMU") for alleged wage and hour violations. The Action was filed by former MSMU employee Xxxxx Xxxxxxx (“Plaintiff”) and seeks (1) unpaid wages (including without limitation, pay for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors (“Class Members”) who worked for MSMU during the Class Period (January 25, 2018 through ); and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct employees who worked for MSMU during the PAGA Period (Octboer 26, 2020 through ) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMU’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMU’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not work during the PAGA Period.) The above estimates are based on MSMU’s records showing that you worked pay periods during the Class Period and you worked pay periods during the PAGA Period. If you believe that you worked more pay periods during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMU. If you worked for MSMU during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June , 2023 By: Xxxxxx Xxxxxxxxx2022 ____________________ Xxxxxxx Xxxxxxx, Interim Vice President of Administration and Finance Plaintiff Dated: 6/30/2023 , 2022 ____________________ Name: Xxxxxxx X Xxxxx Xxxxxxx Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys for Plaintiff President & CEO You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University defendant TravelStore, Inc. ("MSMU"defendant is referred to as “TravelStore”) for alleged wage and hour violations. The Action was filed by a former MSMU employee Xxxxx TravelStore employee, Xxxxxxx Xxxxxxx (“Plaintiff”) ), and seeks payment of (1) unpaid back wages (including without limitationand other relief for a class of hourly-paid, pay for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors non-exempt employees (“Class Members”) who worked for MSMU TravelStore in California during the Class Period (January 25February 28, 2018 through 2017 to [insert date]); and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct all hourly-paid, non-exempt employees who worked for MSMU TravelStore in California during the PAGA Period (Octboer 26February 28, 2020 through to [insert]) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU TravelStore to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU TravelStore to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUTravelStore’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ (less withholding) and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUTravelStore’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMUTravelStore’s records showing that you worked pay periods workweeks during the Class Period and you worked pay periods workweeks during the PAGA Period. If you believe that you worked more pay periods workweeks during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU TravelStore to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUTravelStore. If you worked for MSMU TravelStore during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP Code of Civil Procedure section 583.330 to extend the date to bring a case to trial under CCP Code of Civil Procedure section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June _03/04/2024 By: Dated: 03/04/2024 By: Dated: March 6, 2023 2024 By: Xxxxxxx Xxx, Esq. Shunt Tatavos-Gharajeh, Esq. Xxxxx Xxxxxxx, Esq. Dated: By: On behalf of Motivational Systems, Inc. Dated: By: Xxxxxx XxxxxxxxxXxxxxx, Interim Vice President of Administration and Finance Esq. Xxxxxxx Xxxxxx, Esq.. Dated: 6/30/2023 Xxxxx Xxxxxxx DatedBy: Dated: June 30By: Dated: By: Xxxxxxx Xxx, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Esq. Shunt Tatavos-Gharajeh, Esq. Xxxxx Xxxxxxx, Esq. Dated: _March 19, 2024 By: On behalf of Motivational Systems, Inc. Dated: By: Xxxxxx Xxxxxx, Esq. Xxxxxxx X. XxxxxXxxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys for Plaintiff Esq.. You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University Defendant Motivational Systems, Inc. ("MSMU"“Defendant”) for alleged wage and hour violations. The Action was filed by former MSMU employee Xxxxx Plaintiffs Xxxxxxx Xxxxxxx and Xxxxxx Xxxxxxx (“PlaintiffPlaintiffs”) and ), former employees of Defendant. The Action seeks payment of: (1) unpaid wages for a class of current and former hourly-paid or non-exempt employees of Defendant within the State of California at any time during the period from November 10, 2018, through January 26, 2024 (including without limitation, pay for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors (“Class,” “Class Members,” “Class Period”) who worked for MSMU during the Class Period (January 25, 2018 through ); and (2) penalties under the California Private Attorney Attorneys General Act of 2004 (“PAGA”) for adjunct all current and former hourly-paid or non-exempt employees who worked for MSMU of Defendant within the State of California at any time during the PAGA Period (Octboer period from September 18, 2022, through January 26, 2020 through ) 2024 (“Aggrieved Employees” and “PAGA Period”). Unless you choose to opt out of the settlement by following the procedures described below, you will be deemed a Class Member and, if the Court grants final approval of the settlement, you will be mailed a check for your share of the settlement fund. The proposed Final Approval Hearing on the adequacy, reasonableness, and fairness of the Settlement will be held at in Department C-74 of the San Diego County Superior Court located at 330 West Broadway, San Diego, California 92101. Please also note that the Final Fairness Hearing may be rescheduled by the Court to another date and/or time. Please visit the Administrator’s website at any scheduling changes. for The settlement has two main parts: (1) a Class Settlement requiring MSMU Defendant to fund Individual Class Payments, ; and (2) a PAGA Settlement requiring MSMU Defendant to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”)Payments. Based on MSMUDefendant’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ (less withholding for state and federal taxes) and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUDefendant’s records records, you are not eligible for an Individual PAGA Payment under the Settlement settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMUDefendant’s records showing that you worked pay periods Workweeks during the Class Period and you worked pay periods Pay Periods during the PAGA Period. If you believe that you worked more pay periods Workweeks or Pay Periods during either period, you can submit a challenge by the deadline date. See Section 4 of this Class Notice. The Court has already preliminarily approved the proposed Settlement settlement and approved this Class Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or do not act. Read this Class Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement settlement and how much of the Settlement settlement will be paid to Plaintiff Plaintiffs and Plaintiff’s Plaintiffs’ attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU Defendant to make payments under the Settlement settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUDefendant. If you worked for MSMU Defendant during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:three
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June 8/7/2023 DEFENDANT LYNEER STAFFING SOLUTIONS, 2023 LLC By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration Xxx Xxxxxxx Its: Chief Financial Officer and Finance Dated: 6/30/2023 Xxxxx Xxxxxxx authorized representative PLAINTIFF Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAWXXXXXX XXXXXX LAW, P.C. Xxxxxx Dated: LAW OFFICE OF XXXXXXX XXXXX, APC LAW OFFICES OF XXXXX XXXXXXXX XX By: Xxxxxxx Xxx Xxxxx Xxxxx Xxxxxxxx Attorneys XX Attorney for Plaintiff Xxxxx Xxxxxxxxx You may be eligible to receive money from an employee a class action lawsuit (“Action”) against Mount Saint Mary’s University Lyneer Staffing Solutions, LLC ("MSMU"“Defendant”) for alleged wage and hour violations. The Action was filed by former MSMU employee Xxxxx Xxxxxxx Xxxxxxxxx (“Plaintiff”) and seeks (1) unpaid payment of wages (including without limitation, pay for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors (“Class Members”) who worked for MSMU during the Class Period (January 25, 2018 through ); and (2) penalties under the California Labor Code (“Labor Code”) and the California Private Attorney Attorneys General Act (“PAGA”) for adjunct those that were temporary employees who worked placed to work for MSMU Oxgord Incorporated at 00000 X. Xxxxxx Xxxx., Xxxxxxx, Xxxxxxxxxx 00000, at any time during the PAGA Period Class Period, from June 4, 2018 to December 1, 2019 (Octboer 26“Class Members” as related to the Labor Code, 2020 through ) (“Aggrieved Employees”” as related to the PAGA). The proposed Settlement, if fully approved by this Court, will require Defendant to fund a Gross Settlement Fund that has two main parts: (1) a Class Settlement requiring MSMU to fund portion for payment of Individual Class Payments, and (2) a PAGA Settlement requiring MSMU to fund portion for payment of Individual PAGA Payments and to pay penalties monies to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUDefendant’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ and your Individual individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUDefendant’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMU’s records showing that you worked pay periods during the Class Period and you worked pay periods during the PAGA Period. If you believe that you worked more pay periods during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU Defendant to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUDefendant. If you worked were a temporary employee of Xxxxxx Xxxxxxxx Solutions and placed to work for MSMU Oxgord Incorporated, located at 00000 X. Xxxxxx Xxxx., Xxxxxxx, Xxxxxxxxxx 00000 at any time during the Class Period and/or the PAGA Period, from June 4, 2018 to December 1, 2019, you have two basic options under the Settlement:
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Samples: Class Action Settlement Agreement
Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY March 17, 2023 Dated: June , 2023 By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration and Finance Dated: 6/30/2023 Xxxxx _______________ ___________________________________ Xxxxxxxx Xxxx Xxxxxxx Dated: March 17, 2023 XXXXXXXX & XXXXXXXX, APC By: Xxxx X. Xxxxxxxx Xxxxx Xxxxxxxxxxx Ly Attorneys for Plaintiff, the Proposed Class, and all aggrieved employees Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys for Plaintiff _______________ _________________________ Purple Eagle LLC You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University Purple Eagle LLC ("MSMU"“Defendant” or “Purple Eagle” is used herein as a placeholder) for alleged wage and hour violations. The Action was filed by a former MSMU Purple Eagle employee Xxxxx Xxxxxxxx Xxxx Xxxxxxx (“Plaintiff”) and seeks payment of (1) unpaid wages including minimum wages and overtime wages; (including without limitation, pay 2) rest period penalties; (3) penalties for all hours worked, premium pay resulting from failing failure to authorize provide accurate itemized wage statements; (4) unreimbursed expenses; (5) waiting time penalties; and permit paid rest breaks, and, when applicable, payment other relief for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors a class of hourly employees (“Class Members”) who worked for MSMU Purple Eagle during the Class Period (January 25October 26, 2018 through 2017, to .); and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct all hourly employees who worked for MSMU Purple Eagle during the PAGA Period (Octboer October 26, 2020 through 2020, to .) (“Aggrieved Employees”). The proposed Settlement resolves a highly contested lawsuit. Defendant believes they have complied with the law in all respects and deny any liability for the claims asserted by Plaintiff. Defendant is not admitting liability of any of the factual and legal allegations asserted in the lawsuit, and denies that the lawsuit should proceed as a class action for any purpose other than this Settlement. After investigating the claims at issue, and the possible defenses to those claims, the Parties have agreed to settle this case in order to avoid the cost and risk of further litigation. In view of the costs and risks that continued litigation would entail, Plaintiff and his counsel believe the Settlement is in the best interests of all non-exempt hourly employees who worked for Defendant in California during the Class Period and the PAGA Period. The Settlement avoids costs and risks of continuing the lawsuit; pays money to employees; and, in exchange, releases Defendant from liability from the claims asserted in this lawsuit. The Court has not made a ruling on the merits of the case. The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU Defendant to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU Defendant to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUDefendant’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUDefendant’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMUDefendant’s records showing that you worked pay periods workweeks during the Class Period and you worked pay periods during the PAGA Period. If you believe that you worked more workweeks and/or pay periods during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU Defendant to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUDefendant. If you worked for MSMU Purple Eagle during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June , 2023 By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration and Finance Dated: 6/30/2023 Xxxxxxxx Xxxxxxxx-Xxxxx Xxxxxxx Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx For Plaintiff For MASI Xxx Xxxxxxxx Attorneys for Counsel For Plaintiff Counsel For MASI Xxxx Xxxxxxxx, Esq. You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University Media All Stars, Inc. ("MSMU"abbreviate name; “MASI” is used herein as a placeholder) for alleged wage and hour violations. The Action was filed by a former MSMU MASI employee Xxxxxx Xxxxxx Xxxxxxxx-Xxxxx Xxxxxxx (“Plaintiff”) and seeks payment of (1) unpaid back wages (including without limitation, pay and other relief for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors a class of employees (“Class Members”) who worked for MSMU MASI during the Class Period (January 25December 16, 2018 through 2017 to {date of preliminary approval} ); and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct all employees who worked for MSMU MASI during the PAGA Period (Octboer 26December 16, 2020 through 2017 to {date of preliminary approval}) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU MASI to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU MASI to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUMASI’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ (less withholding) and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMU’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not work during the PAGA Period.) The above estimates are based on MSMU’s XXXX’x records showing that you worked pay periods workweeks during the Class Period and you worked pay periods workweeks during the PAGA Period. If you believe that you worked more pay periods workweeks during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU MASI to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUMASI. If you worked for MSMU MASI during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP section 583.330 to extend the date to bring a case to trial under CCP section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY 9/6/2022 By: Plaintiff Xxxxxx Xxxxxxx Dated: June By: Elite Nursing Services, 2023 Inc. Name: Title: Dated: By: Xxx Xxxxxxxx AS TO FORM: Dated: 8/3/22 By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration and Finance Xxxxxxxx Xxxxxxxx Law Firm Counsel for Plaintiff Dated: 6/30/2023 By: Xxxxxxxx Xxxxxxx Xxxx X. Xxxxx Xxxxxxx Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys Xxxxx & Xxxxxx L.L.P. Counsel for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys for Plaintiff Defendants You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University Defendants Elite Nursing Services, Inc. ("MSMU"“Elite”) and Xxx Xxxxxxxx (collectively, “Defendants”) for alleged wage and hour violations. The Action was filed by a former MSMU Elite employee Xxxxx Xxxxxx Xxxxxxx (“Plaintiff”) and seeks payment of (1) unpaid back wages (including without limitation, pay and other relief for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors a class of non-exempt employees (“Class Members”) who worked for MSMU Elite and were assigned to work at any facility inside California during the Class Period (January 25February 4, 2018 through to [60 days from the date the Settlement Agreement is signed, or the date of preliminary approval, whichever occurs earlier]); and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct all non-exempt employees who worked for MSMU Elite during the PAGA Period (Octboer 26February 14, 2020 through 2021to [60 days from the date the Settlement Agreement is signed, or the date of preliminary approval, whichever occurs earlier]) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU Elite to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU Elite to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUElite’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ (less withholding) and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUElite’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMUElite’s records showing that you worked pay periods workdays during the Class Period and you worked pay periods workdays during the PAGA Period. If you believe that you worked more pay periods workdays during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU Elite to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUDefendants. If you worked for MSMU Elite during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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Stay of Litigation. The Parties agree that upon the execution of this Agreement the litigation shall be stayed, except to effectuate the terms of this Agreement. The Parties further agree that upon the signing of this Agreement that pursuant to CCP Code of Civil Procedure section 583.330 to extend the date to bring a case to trial under CCP Code of Civil Procedure section 583.310 for the entire period of this settlement process. MOUNT SAINT MARY’S UNIVERSITY Dated: June , 2023 By: Xxxxxx Xxxxxxxxx, Interim Vice President of Administration and Finance Dated: 6/30/2023 Xxxxx Xxxxxxx Dated: Dated: June 30, 2023 XXXXXXX BRANCH BELL + XXXXXXX LLP Xxxxxxx X. Xxxxx, Attorneys for Defendant HAMMONDLAW, P.C. Xxxxxx Xxxxxxx Xxx Xxxxxxxx Attorneys For Plaintiff For XYZ (date) Counsel for Plaintiff Counsel for XYZ (date) [ (case name and number) ] You may be eligible to receive money from an employee class action lawsuit (“Action”) against Mount Saint Mary’s University ("MSMU"abbreviate name; “XYZ” is used herein as a placeholder) for alleged wage and hour violations. The Action was filed by former MSMU a[n][former] XYZ employee Xxxxx Xxxxxxx (“Plaintiff”) and seeks payment of (1) unpaid back wages (including without limitation[and other relief] for a class of [e.g., pay for all hours worked, premium pay resulting from failing to authorize and permit paid rest breaks, and, when applicable, payment for all wages due at termination), penalties, and unreimbursed remote work/business expenses, incurred by adjunct instructors hourly] employees (“Class Members”) who worked for MSMU XYZ during the Class Period (January 25, 2018 through )to ; and (2) penalties under the California Private Attorney General Act (“PAGA”) for adjunct all [e.g., hourly] employees who worked for MSMU XYZ during the PAGA Period (Octboer 26, 2020 through ( to ) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring MSMU XYZ to fund Individual Class Payments, and (2) a PAGA Settlement requiring MSMU XYZ to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”). Based on MSMUXYZ’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $ (less withholding) and your Individual PAGA Payment is estimated to be $ . The actual amount you may receive likely will be different and will depend on several a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to MSMUXYZ’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not didn’t work during the PAGA Period.) The above estimates are based on MSMUXYZ’s records showing that you worked pay periods workweeks during the Class Period and you worked pay periods workweeks during the PAGA Period. If you believe that you worked more pay periods workweeks during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiff and Plaintiff’s attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires MSMU XYZ to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against MSMUXYZ. If you worked for MSMU XYZ during the Class Period and/or the PAGA Period, you have two basic options under the Settlement:
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