Important Dates and Deadlines
Opt-Out Deadline
You Can Opt Out of the Class Settlement but not the PAGA Settlement.
If you don’t want to fully participate in the proposed Settlement, you can opt out of the Class Settlement by sending the Administrator a written Request for Exclusion. Once excluded, you will be a Non-Participating Class Member and no longer eligible for an Individual Class Payment. Non-Participating Class Members cannot object to any portion of the proposed Settlement. See Section 12 of this Notice.
You cannot opt out of the PAGA portion of the proposed Settlement. Defendants must pay Individual PAGA Payments to all PAGA Claimants and the PAGA Claimants must give up their rights to pursue PAGA claims.
Objection Deadline
Participating Class Members Can Object to the Class Settlement but not the PAGA Settlement.
All Class Members who do not opt out (“Participating Class Members”) can object to any aspect of the proposed Settlement. The Court’s decision whether to finally approve the Settlement will include a determination of how much will be paid to Class Counsel and Plaintiffs who pursued the Action on behalf of the Class. You are not personally responsible for any payments to Class Counsel or Plaintiffs, but every dollar paid to Class Counsel and Plaintiffs reduces the overall amount paid to Participating Class Members. You can object to the amounts requested by Class Counsel or Plaintiffs if you think they are unreasonable. See Section 13 of the FAQ
Submit Claim Form
If you complete a Claim Form, you will be a Participating Class Member, eligible for an Individual Class Payment and an Individual PAGA Payment (if any).
You can visit the Claim Form section on the Settlement Website to provide additional information about your business-related expenditures and time spent.
Challenge the Calculations of Your Registered Weeks/Pay Periods
The amount of your Individual Class Payment and PAGA Payment (if any) depend in part on how many weeks you were registered with R+F as a Consultant for at least one day during the Class Period and how many Pay Periods you were registered with R+F as a Consultant for at least one day during the PAGA Period, respectively. The number of Class Period Registered Weeks and number of PAGA Registered Periods you were registered for according to Defendant’s records is stated on the first page of this Notice. If you disagree with either of these numbers, you must challenge it by September 26, 2025. See Section 6 of the FAQs
Final Approval Hearing
The Court’s Final Approval Hearing is scheduled to take place on October 31, 2025. You don’t have to attend but you do have the right to appear (or hire an attorney to appear on your behalf at your own cost), in person, or by using the Court’s virtual appearance platform via Zoom. Participating Class Members can verbally object to the Settlement at the Final Approval Hearing.