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1 LEGAL NOTICE: If you worked for PLS Financial Solutions of California, Inc. (formerly Payday Loan Store of California, Inc.) or PLS Check Cashers of California, Inc. as an hourly paid or non exempt employee in California during some or all of the period from January 6, 2010 through April 10, 2015, a class action settlement will affect your rights A court authorized this Notice. Dieguez, et al. v. Payday Loan Store of California, Inc., et al., Case No. BC YOU ARE HEREBY NOTIFIED that a proposed class settlement (the Class Settlement ) of the above entitled purported class action ( the Action ) filed in the Los Angeles County Superior Court ( the Court ) has been reached by the Parties and granted Preliminary Approval by the Court. The proposed Class Settlement will resolve all class claims in this Action. The Court ordered this Notice be sent to you because you may be a Class Member. This Notice informs you of the settlement and your legal rights under the Class Settlement. SUMMARY OF CASE Three former non exempt employees ( Class Representatives or Plaintiffs ) sued PLS Financial Solutions of California, Inc. (formerly Payday Loan Store of California, Inc.) and PLS Check Cashers of California, Inc. ( PLS or Defendants ) on behalf of themselves and others similarly situated, and alleged various California Labor Code violations including, but not limited to, unpaid meal and rest premiums, failure to pay all regular and overtime wages, unpaid and/or untimely vacation wages, waiting time penalties, failure to provide and maintain accurate paystubs and civil penalties under the Private Attorney General Act. After extensive investigation and an exchange of relevant information, the Parties agreed to enter into private mediation to try and resolve the claims. The Parties attended mediation and thereafter reached the Class Settlement memorialized in the Joint Stipulation of Settlement and Release on file with the Court, and whose terms are generally summarized in this Notice. If you qualify as a Class Member, you could receive money from the settlement. Your legal rights are affected whether you act or don t act. Read this Class Notice carefully. SUBMIT A CLAIM FORM DO NOTHING EXCLUDE YOURSELF OBJECT HOW MUCH CAN I GET? YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT This is the only way to receive payment from the settlement. In exchange for this payment you will give up any rights to sue for the same claims that were part of this settlement. You will get no money and you will give up any rights to sue for the same claims that were part of this settlement. Give up all benefits, including money, from the settlement. Retain all rights you may have against PLS, explained below. Write to the Court about why you don t agree with the settlement. The Court may or may not agree with your objection. Look at the top of the enclosed Claim Form. Your rights and options and the deadlines to exercise them are explained in this Notice. The Court in charge still has to decide whether to grant final approval of the settlement. If the Court approves the settlement and after any appeals are resolved, payments will be made to Class Members who comply with this Notice by submitting a valid claim form. 1. Why Did I Get This Notice Package? You are not being sued. Plaintiffs sued PLS in a class action on behalf of themselves and similarly situated employees like you. PLS s records show you are a current or former hourly paid or non exempt employee who worked at a PLS store within the state of California during the period from January 6, 2010 through April 10, 2015 (the Class Period ). Questions? Call 1 (888)

2 You received this Notice because you have a right to know about a proposed settlement of a class action lawsuit and about your options before the Court decides whether to grant final approval of the settlement. If the Court approves the settlement, and after any objections and appeals are resolved, a Claims Administrator appointed by the Court will make the payments that the settlement allows. This Notice explains the lawsuit, the settlement, your legal rights, what benefits are available, who is eligible for them and how to get them. 2. What Is This Lawsuit About? The Class Representatives claim, on behalf of themselves and the Class of hourly paid or non exempt employees who worked at a PLS store in California during the Class Period, that PLS: (1) failed to provide meal and rest periods; (2) failed to pay all meal and rest premiums in violation of California labor laws; (3) failed to pay all wages, including regular, vacation, and overtime wages; (4) failed to maintain accurate records; (5) failed to pay penalties, including waiting time and recordkeeping penalties; and (6) violated Labor Code 2698, et seq. ( Private Attorneys General Act of 2004 or PAGA ). 3. Do I Need to Hire an Attorney? You need not hire your own attorney. You are already represented by Class Counsel. At the preliminary approval hearing, the Court appointed the following attorneys as Class Counsel to represent the Class in this Action: Kenneth H. Yoon Stephanie Yasuda Law Offices of Kenneth H. Yoon One Wilshire Blvd., Suite 2200 Los Angeles, CA Tel: (213) John P. Bisnar Brian D. Chase Jerusalem F. Beligan Bisnar Chase LLP 1301 Dove Street, Suite 120 Newport Beach, CA (949) However, you may hire your own attorney at your own expense if you choose to do so. 4. What is PLS s Position? PLS denies all of the Class Representatives allegations, or that it violated any law, and contends that it complied with federal, state and local laws. Specifically, PLS denies that the Class Representatives or Class Members: are owed any additional compensation for the hours they worked, vested vacation wages, or meal and rest period premiums; have been denied meal periods and rest periods; have received inaccurate or deficient wage statements; or have not been timely paid wages upon termination. 5. Why Is There A Settlement? The Court did not decide in favor of Plaintiffs or Defendants. Instead of going to trial, after a thorough investigation into the facts, both sides agreed to a settlement after mediating this case before a neutral, third party mediator. The class claims were settled because Class Counsel and the Class Representatives believe that the terms of the settlement are fair and reasonable in light of the strength and weaknesses of the claims and other factors. 6. How Do I Know If I Am Part Of The Settlement? Class Members are all current and former hourly paid or non exempt employees who worked at a PLS store within California during the period from January 6, 2010 through April 10, What Does The Settlement Provide? The settlement provides that Defendants are willing to pay up to $2,000,000 (the Gross Settlement Amount ) to fully resolve the claims in the Action. Class Members who submit timely and valid Claim Forms will receive Settlement Questions? Call 1 (888)

3 payments from the Net Settlement Amount. The Net Settlement Amount is the portion of the Gross Settlement Amount available for distribution to Class Members who submit timely and valid Claim Forms after deduction of Court approved Class Counsel s attorneys fees and costs, Settlement Administration Costs, the Class Representatives Enhancement Payments and the State of California s portion of the PAGA Payment. Deductions for Class Counsel s Attorneys Fees and Costs, Class Representatives Enhancement Payments, the State of California s portion of the PAGA Payment and Settlement Administration Costs. Class Counsel will ask the Court to award attorneys fees for $666,666.67, which represents thirty five percent (33 1/3%) of the Gross Settlement Amount and litigation costs of up to $25, from the Gross Settlement Amount. In addition, Class Counsel will ask the Court to authorize Enhancement Payments from the Gross Settlement Amount of $10,000 to each Class Representative ($30,000 total) to compensate each for the risks, time and expense of each of their involvement in this Action. This payment is in addition to whatever payment the Class Representatives are otherwise entitled to as Class Members. The State of California will also be paid $10, for its share of the $13, PAGA Payment for claims under the Private Attorneys General Act of The remaining $3, will be distributed to claiming Class Members by adding that sum to the Net Settlement Amount, subject to Court approval. The Claims Administrator will also be reimbursed for the expense of notifying the Class Members of the Settlement, processing claims and requests for exclusions submitted by Class Members and distributing Settlement payments. Settlement Administration Costs are estimated at $27 30,000 but may be higher or lower depending on the results of the claim process. 8. What Can I Get From the Settlement? Claimants will be paid out of the Net Settlement Amount. Twenty five percent (25%) of each Claim Amount will be designated for alleged unpaid wages and other damages, for which IRS Form W 2 shall be issued, and seventy five percent (75%) will be designated for alleged interest and penalties, for which IRS Form 1099 shall be issued, as appropriate. If you submit a complete Claim Form by the Claim Period Deadline, you will receive your share of the Net Settlement Amount after the Court approves the Settlement. Your estimated share, after employer payroll taxes have been deducted, is listed in the enclosed Claim Form. 9. How Was My Share Calculated? Each Claimant s Settlement Share shall be determined by taking the Qualifying Workweeks (which excludes leaves of absence) for the individual Claimant and dividing that by the Qualifying Workweeks for all Class Members and multiplying that fraction by the Net Settlement Amount. Qualifying Workweeks are workweeks worked by Class Members while in a hourly paid or non exempt position for work performed at a PLS store within the state of California. Workweeks shall be defined as the total length of service (in days) during the Class Period divided by seven. Total length of service shall exclude any workweek in which a Class Member reported no hours worked on behalf of Defendants. The calculation of a Class Member s workweeks and a determination whether a Class Member was actively employed in a particular workweek will be determined from Defendants records. 10. How Can I Get Payment? To qualify for payment, you must complete and return a Claim Form. A Claim Form is enclosed with this Notice. Read the instructions carefully, fill out the Claim Form completely, sign and date it, and mail it postmarked to the Claims Administrator no later than August 24, Alternatively, you may submit a Claim Form online at by completing the procedures on the website and receiving a confirmation number no later than 11:59 pm, August 24, If you do nothing or fail to timely and properly submit your Claim Form, you will be included in the settlement Class, and be bound by the terms of the settlement (including the Released Claims described in Section 12 below), but will not receive money. Questions? Call 1 (888)

4 California law protects Class Members from retaliation based on their decision to participate in a class action settlement. 11. When Would I Get My Payment? The Court will hold the Final Approval Hearing on or about September 3, 2015 at 1:30 p.m. in Department 307 of the Los Angeles Superior Court, 600 S. Commonwealth Avenue, Los Angeles, California 90005, to decide whether to approve the settlement. If the Court approves the settlement on that date, your settlement share will be mailed to you within approximately 100 days from that date, unless there are objections or appeals. If there are objections or appeals, it is always uncertain when they will be resolved, and resolving them can take time. 12. What Rights Do I Give Up If I Participate Or Do Nothing? Unless you exclude yourself, you will remain a Class Member, and you will be bound by the settlement, including the Released Claims described below. That means you cannot sue, or to continue to sue, or be part of any other lawsuit related to the Released Claims. It also means that all of the Court s orders will apply to you and legally bind you. Released Claims Upon the final approval by the Court of the settlement, unless you submit a valid and timely opt out request, you will be deemed to have fully, finally, and forever released PLS, and their past, present and/or future, direct and/or indirect, officers, directors, employees, agents, representatives, attorneys, insurers, partners, investors, shareholders, Claims Administrators, parent companies, subsidiaries, affiliates, divisions, predecessors, successors, and/or assigns ( Releasees ) from all claims that were or could have been pled based on the factual allegations in the Complaint against Defendants while in an hourly paid or non exempt position for work performed at a PLS store within the state of California and during the period from January 6, 2010 through April 10, 2015, including without limitations claims for unpaid wages and overtime, untimely final paychecks, record keeping violations, itemized wage statements, meal and rest period wages and premiums, unpaid and/or untimely vacation wages, and restitution and penalties under PAGA. No other claims (except for attorneys fees and costs) will be released as part of this settlement. The Released Claims include no claims related to work performed while not a Class Member (e.g., for work performed while classified as exempt from overtime requirements, for work performed outside California, etc.) 13. How Do I Exclude Myself From The Settlement? If you do not wish to participate in the settlement, you may exclude yourself (called opting out ) by submitting a written opt out request to the Claims Administrator. Your request to opt out must: (a) state the name and the last four digits of your Social Security number; (b) a statement you wish to be excluded from the Class in Dieguez v. PLS; (c) be signed; and (d) be post marked no later than August 24, You must sign the opt out request personally and may not have someone sign for you, nor may you submit an opt out request on behalf of a group. Your opt out request must be signed and returned via United States first class mail postmarked no later than August 24, 2015 to: Dieguez v. PLS Class Action Settlement C/O CPT Group, Inc Aston Irvine, CA Phone: 1 (888) If you submit a timely opt out request, then upon its receipt you will no longer be a member of the Class, you will be barred from participating in any portion of the settlement, you may not object to the settlement, and you will receive no benefits, including money, from the settlement. If you wish, you may pursue, at your own expense, any claims you may have against PLS. If you do not submit a complete and timely written opt out request, you will be included in the Class, Questions? Call 1 (888)

5 and you will be bound by the terms of the settlement (including the Released Claims described in Section 12 above), whether or not you filed a Claim Form and/or objected to the settlement. Do not submit both the Claim Form and an opt out request. If you submit both, the opt out request will be valid, and you will be excluded from the settlement class. 14. When Is The Final Approval Hearing? The Court will hold a Final Approval Hearing in Department 307 of the Los Angeles Superior Court, 600 S. Commonwealth Avenue, Los Angeles, California 90005, on September 3, 2015 at 1:30 p.m. or such other, later date as the Court may authorize, to determine whether the settlement is fair, reasonable, and adequate; and if there are objections, the Court will consider them. The Court will also be asked to approve Class Counsel s request for attorneys fees and litigation costs, the Class Representatives Enhancement Payments, the PAGA Payment and the Settlement Administration Costs. The hearing may be continued without further notice to Class Members. You are not required to attend the Final Approval Hearing. 15. How Do I Object To The Settlement And Appear At The Final Approval Hearing? You may object to the terms of the settlement before the Final Approval Hearing. However, if the Court rejects your objection, you will still be bound by the settlement. To object, you must file a written objection with the Clerk of the Los Angeles Superior Court, 600 S. Commonwealth Avenue, Los Angeles, California 90005, and send copies via U.S. mail to the following: CLASS COUNSEL KENNETH H. YOON STEPHANIE E. YASUDA LAW OFFICES OF KENNETH H. YOON One Wilshire Blvd., Suite 2200 Los Angeles, California Telephone: (213) JOHN P. BISNAR BRIAN D. CHASE JERUSALEM F. BELIGAN BISNAR CHASE LLP 1301 Dove Street, Suite 120 Newport Beach, California Telephone: (949) PLS S ATTORNEYS TIMOTHY J. LONG SHAUNICIE S. FIELDER ORRICK, HERRINGTON & SUTCLIFFE LLP 777 S. Figueroa Street, Suite 3200 Los Angeles, California Telephone: (213) Any written objection shall state each reason to support your objection and any legal support for each objection. Your objection must also state your full name, address, telephone number, and the approximate dates of your employment at PLS. To be valid and effective, any objections to approval of the settlement must be filed with the Court and served upon each of the above listed attorneys by U.S. mail postmarked no later than August 24, DO NOT TELEPHONE THE COURT. You do not have to attend the hearing, but you may do so at your own expense. If you file an objection, you do not have to appear at the hearing. As long as you filed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary. If you want to speak at the Final Approval Hearing, you must ask the Court for permission. The Court will decide whether you may do so. To request permission to appear at the hearing, you must file a request titled Notice of Intention to Appear in Dieguez v. PLS, Case No. BC with the Los Angeles Superior Court, and deliver copies to Class Counsel and PLS s Attorneys at the addresses listed above. Include your name, address, telephone number, signature, and if you Questions? Call 1 (888)

6 have not filed an objection, a brief statement of the position you wish to put before the Court at the Final Approval Hearing and the basis for that position. Your Notice of Intention to Appear must be filed with the Court and served upon the above attorneys by U.S. mail postmarked no later than August 24, If the Court approves the settlement despite any objections, and you have not submitted your Claim Form, you will receive no settlement proceeds but you will be bound by the terms of the settlement (including the Released Claims described in Section 12 above). If you intend to object, but also wish to receive your share of the settlement proceeds, you must timely submit your Claim Form as stated above. You cannot both object and opt out. If you submit both an opt out request and objection, the opt out request will be valid, and you will be excluded in from the settlement class. 16. How Do I Get Additional Information? The above is a summary of the basic terms of the settlement. For the precise terms and conditions of the settlement, consult the detailed Joint Stipulation of Settlement and Release between Plaintiffs and Defendants, which is on file with the Clerk of the Court. The pleadings and all other records from this litigation may be examined by visiting the Los Angeles Superior Court at 600 S. Commonwealth Avenue, Los Angeles, California during regular office hours (Mon. Fri., 8:30 a.m. to 4:30 p.m.) You may also view some of the key documents at If you have questions, you can call the Claims Administrator at 1 (888) or any of Class Counsel (see Section 15 for phone numbers.) PLEASE DO NOT WRITE OR TELEPHONE THE COURT OR THE OFFICE OF THE CLERK FOR INFORMATION REGARDING THIS SETTLEMENT OR THE CLAIM PROCESS. DATED: July 9, 2015 BY ORDER OF THE COURT HON. WILLIAM F. HIGHBERGER SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES Questions? Call 1 (888)

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