THE TERMS OF THE SETTLEMENT. To avoid the time and expense of further litigation, Plaintiff and Defendants have agreed to resolve the litigation. The Settlement is the product of extensive negotiations between the parties, who were assisted in their negotiations by a neutral private mediator. The parties have taken into account the uncertainty and risks of litigation and have concluded that it is desirable to settle on the terms and conditions set forth in the Settlement Agreement. If the Settlement is approved by the Court, the Settlement Class will obtain the benefits of the Settlement without the further delay and uncertainty of additional litigation. The Settlement resolves all issues regarding the Plan’s inclusion of Chesapeake Stock. The terms of the Settlement are set forth in the Class Action Settlement Agreement dated April 18, 2022 (the “Settlement Agreement”), which is available on the Settlement Website at xxxx://xxx.xxxxxxxxxxxxxxxxxxxxxx.xxx. Those terms are summarized below. This Notice is a summary, and in the event of any inconsistency, the Settlement Agreement controls. Nothing in the Settlement Agreement is an admission or concession on Defendants’ part of any fault or liability, nor is it an admission or concession on Plaintiff’s part that his claims lacked merit.
THE TERMS OF THE SETTLEMENT. To avoid the time and expense of a lawsuit, Plaintiffs and Defendants have agreed to a settlement that involves both monetary payments to Plan participants and changes in the investment options and fees of the Plan. These and other terms of the Settlement are set forth in the Class Action Settlement Agreement dated May 19, 2016 (“Settlement Agreement”), and described below.
THE TERMS OF THE SETTLEMENT. 7. What is the settlement amount? Page 4 8. How much will my Individual Settlement Payment be? Page 4
THE TERMS OF THE SETTLEMENT. 7. What is the settlement amount? Under the proposed Settlement, Simplot will pay $950,000 (referred to as the “Maximum Settlement Amount” or “MSA”) to fully and finally resolve all claims in the Lawsuit.
THE TERMS OF THE SETTLEMENT. Pursuant to the terms of the Settlement, and based on an analysis of Defendant’s timekeeping and payroll records, Defendant has agreed to pay you a gross amount of $ (“Settlement Payment”). If the Court approves the Parties’ settlement, a check for this amount will be mailed to you. Under the tax laws, your Settlement Payment constitutes earned wages. Thus, your payment will be issued in the form of a payroll check subject to all ordinary employee taxes and withholdings. YOU DO NOT NEED TO DO ANYTHING IN ORDER TO RECEIVE THIS SETTLEMENT PAYMENT. UNLESS YOU EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS, YOU WILL RECEIVE THE AMOUNT STATED ABOVE.
THE TERMS OF THE SETTLEMENT. This case has been pending since November 2017. To avoid prolonging the litigation further, Plaintiff and Defendants have agreed to a settlement. Plaintiff’s claims in the lawsuit involve the investment options in the Plans, which offered investments that Plaintiff alleges were imprudent and charged excessive fees. The Settlement covers the 403(b) Plan, the 401(a) Plan, and the 401(k) Plan and resolves all issues regarding the prudence and fees charged by the Plans from November 28, 2011 until the present time. Assuming the Settlement is approved by the Court, settling the case means that monetary relief will be distributed to the Settlement Class, and without the further delay and uncertainty of additional litigation. The terms of the Settlement are set forth in the Class Action Settlement Agreement, dated January 25, 2019 (“Settlement Agreement”), which is available at www. .com, and are summarized below.
THE TERMS OF THE SETTLEMENT. 6. What claims are covered by the Settlement? The Settlement will resolve all of the claims Settlement Class Members could have brought against FPG with respect to any deductions that were made by FPG for worker’s compensation/industrial insurance benefits premiums (the “Release Claims”). The Released Claims specifically include, but are not limited to, any claims arising out of or relating to a failure to pay wages on account of such deductions, a failure to timely pay all wages due on account of such deductions, any alleged violation of the Washington Industrial Welfare Act or Washington Industrial Insurance Act (whether arising under Title 49 RCW, Title 51 RCW, or otherwise) on account of such deductions, any alleged unjust enrichment or misappropriation on account of such deductions, as well as any attendant claims for unpaid wages, premium payments, penalties, interest, exemplary damages, and attorney’s fees and costs’ relating to each of the foregoing.
THE TERMS OF THE SETTLEMENT. 6. What claims are covered by the Settlement? The Settlement will resolve all of the claims Settlement Class Members could have brought against FPG with respect to any deductions that were made by FPG for worker’s compensation/industrial insurance benefits premiums (the “Release Claims”). The Released Claims specifically include, but are not limited to, any claims arising out of or relating to a failure to pay wages on account of such deductions, a failure to timely pay all wages due on account of such deductions, any alleged violation of the Washington Industrial Welfare Act or Washington Industrial Insurance Act (whether arising under Title 49 RCW, Title 51 RCW, or otherwise) on account of such deductions, any alleged unjust enrichment or misappropriation on account of such deductions, as well as any attendant claims for unpaid wages, premium payments, penalties, interest, exemplary damages, and attorney’s fees and costs’ relating to each of the foregoing. In addition, as to the Settlement Subclass, “Released Claims” shall also include any and all claims, whether known or unknown, that were brought or that could have been brought based on any facts alleged in the Case with respect to a failure to pay for all hours worked (whether due to a failure to pay for allegedly compensable on-call time, a failure to pay for time spent working outside the normal workday, or otherwise), as well as any and all claims that were brought or that could have been brought based on any facts alleged in the Case with respect to a failure to provide meal periods and/or rest breaks. As it relates to the Subclass, the Released Claims specifically include, but are not limited to, any claims alleging a failure to pay for all hours worked, a failure to timely pay for all wages when due, a failure to pay all wages arising out of or relating to any alleged missed, interrupted, shortened, untimely, unpaid, and/or non-compliant rest breaks and/or meal periods, as well as any attendant claims for unpaid wages, overtime payments, premium payments, interest, exemplary damages, and attorney’s fees and costs’ relating to each of the foregoing.
THE TERMS OF THE SETTLEMENT. 6. What claims are covered by the Settlement? The Settlement will resolve all of the claims Plaintiffs and Members of the Settlement Classes could have brought against Pyramid regarding any wage and hour or consumer protection violation under state and local law, including, for example, failure to allow rest or meal periods that comply with WAC 296‐126‐092, failure to pay for all hours worked, including time spent waiting between shifts for the benefit of Pyramid and off‐the‐clock work, failure to pay overtime compensation, failure to pay service charges, and any assertion of rights related to these claims.
THE TERMS OF THE SETTLEMENT. 6. What claims are covered by the Settlement? The Settlement will resolve all of the claims Settlement Class Members could have brought against EOH regarding: (1) an alleged failure to provide the rest breaks required by Washington law; and
