Frequently Asked Questions

1. What is the Action about?

Plaintiffs are former employees of Defendants. The Action accuses Defendants of violating California labor laws for failure to pay overtime wages at the correct rate; failure to pay double time wages at the correct rate; failure to pay overtime and/or double time wages by failing to include all applicable remuneration in calculating the regular rate of pay; failure to provide meal periods; failure to provide rest periods; failure to pay premium wages for missed meal and rest periods; failure to provide with accurate written wage statements; failure to pay wages due, negotiable and payable in cash on demand; failure to provide employment records for inspection; failure to provide with reporting time pay; failure to pay split shift payments; failure to pay sick time pay at the correct rate; failure to provide notice of paid sick time; failure to reimburse them with necessary business expenditures; and failure to pay all of their final wages following separation of employment in violation of Labor Code §§ 201, 202, 203, 204, 210, 212, 213, 215, 216, 218.6, 223, 225, 226, 226.6, 226.7, 226(a), 246, 354, 408, 432, 510, 512, 553, 1174, 1175, 1182.2, 1194, 1194.2, 1197, 1197.1, 1198, 1198.5, 2800 and 2802 as well as California Code of Regulations, Title 8 section 11050(5)(A) and 11050(4)(C) and Bus. & Prof. Code sections 17200 and 17203.

Based on the same claims, Plaintiffs have also asserted a claim for civil penalties under the California Private Attorneys General Act (Labor Code §§ 2698, et seq.) (“PAGA”). Plaintiffs are represented by attorneys in the Action: Haig B. Kazandjian, Cathy Gonzalez, and Melissa Robinson of Haig B. Kazandjian Lawyers, APC and Emil Davtyan, David Yeremian, David Keledjian, and David Arakelyan of D.Law, Inc. (“Class Counsel.”)

Defendants strongly deny violating any laws or failing to pay any wages and contends it complied with all applicable laws.

2. What does it mean that the Action has settled?

So far, the Court has made no determination whether Defendants or Plaintiffs are correct on the merits. In the meantime, Plaintiffs and Defendants hired an experienced, neutral mediator in an effort to resolve the Action by negotiating an to end the case by agreement (settle the case) rather than continuing the expensive and time-consuming process of litigation. The negotiations were successful. By signing a lengthy written settlement agreement ("Agreement") and agreeing to jointly ask the Court to enter a judgment ending the Action and enforcing the Agreement, Plaintiffs and Defendants have negotiated a proposed Settlement that is subject to the Court’s Final Approval. Both sides agree the proposed Settlement is a compromise of disputed claims. By agreeing to settle, Defendants do not admit any violations or concede the merit of any claims.

Plaintiffs and Class Counsel strongly believe the Settlement is a good deal for you because they believe that: (1) Defendants have agreed to pay a fair, reasonable and adequate amount considering the strength of the claims and the risks and uncertainties of continued litigation; and (2) Settlement is in the best interests of the Class Members and Aggrieved Employees. The Court preliminarily approved the proposed Settlement as fair, reasonable and adequate, authorized the Notice, and scheduled a hearing to determine Final Approval.

3. What are the important terms of the proposed Settlement?

1. Defendants Will Pay $715,00.00 as the Gross Settlement Amount (“Gross Settlement”). Defendants have agreed to deposit the Gross Settlement into an account controlled by the Administrator of the Settlement. The Administrator will use the Gross Settlement to pay the Individual Class Payments, Individual PAGA Payments, Class Representative Service Payment, Class Counsel’s attorney’s fees and expenses, the Administrator’s expenses, and penalties to be paid to the California Labor and Workforce Development Agency (“LWDA”). Assuming the Court grants Final Approval, Defendants will fund the Gross Settlement not more than 30 days after the Judgment entered by the Court becomes final. The Judgment will be final on the date the Court enters Judgment, or a later date if Participating Class Members object to the proposed Settlement or the Judgment is appealed.

2. Court Approved Deductions from Gross Settlement. At the Final Approval Hearing, Plaintiffs and/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement, the amounts of which will be decided by the Court at the Final Approval Hearing:

   1. Up to $250,250.00 (35% of the Gross Settlement) to Class Counsel for attorneys’ fees and up to $35,000.00 for their litigation expenses. To date, Class Counsel have worked and incurred expenses on the Action without payment.

   2. Up to $10,000.00 as Class Representative Awards to each Plaintiff for filing the Action, working with Class Counsel and representing the Class (combined total $30,000.00). The Class Representative Awards will be the only monies Plaintiffs will receive other than each Plaintiff’s Individual Class Payment and any Individual PAGA Payments.

   3. Up to $28,973.00 to the Administrator for services administering the Settlement.

   4. Up to $71,500.00 for PAGA Penalties, allocated 75% to the LWDA PAGA Payment ($53,625.00) and 25% in Individual PAGA Payments to the Aggrieved Employees based on their PAGA Period Pay Periods ($17,875.00).

   Participating Class Members have the right to object to any of these deductions. The Court will consider all objections.

3. Net Settlement Distributed to Class Members. After making the above deductions in amounts approved by the Court, the Administrator will distribute the rest of the Gross Settlement (the “Net Settlement”) by making Individual Class Payments to Participating Class Members based on their Class Period Workweeks.

4. Taxes Owed on Payments to Class Members. Plaintiffs and Defendants are asking the Court to approve an allocation of 10% of each Individual Class Payment to taxable wages (“Wage Portion”) and 90% to penalties and interest (“Non-Wage Portion.). The Wage Portion is subject to withholdings and will be reported on IRS W-2 Forms. Defendants will separately pay employer payroll taxes they owe on the Wage Portion. The Individual PAGA Payments are counted as penalties rather than wages for tax purposes. The Administrator will report the Individual PAGA Payments and the Non-Wage Portions of the Individual Class Payments on IRS 1099 Forms.

   Although Plaintiffs and Defendants have agreed to these allocations, neither side is giving Class Members any advice on whether the Settlement Payments are taxable or how much might be owed in taxes. Class Members are responsible for paying all taxes (including penalties and interest on back taxes) on any Payments received from the proposed Settlement. Class Members should consult a tax advisor with any questions about the tax consequences of the proposed Settlement.

5. Need to Promptly Cash Payment Checks. The front of every check issued for Individual Class Payments and Individual PAGA Payments will show the date when the check expires (the void date). Checks not cashed by the void date will be automatically cancelled, and the monies will be deposited with the California Controller's Unclaimed Property Fund in Class Member’s name.

   If the monies represented by a Class Member’s check is sent to the Controller’s Unclaimed Property, please consult the rules of the Fund for instructions on how to retrieve the money.

6. Requests for Exclusion from the Class Settlement (Opt-Outs).Class Members will be treated as a Participating Class Member, participating fully in the Class Settlement, unless they notify the Administrator in writing, not later than April 20, 2026, that they wish to opt-out. The easiest way to notify the Administrator is to send a written and signed Request for Exclusion by the April 20, 2026 Response Deadline. A Request for Exclusion is a letter from a Class Member or his/her/their representative that reasonably communicates the Class Member’s election to be excluded from the Settlement and includes the Class Member’s name, address and email address or telephone number. To be valid, a Request for Exclusion must be timely faxed, emailed, or postmarked by the Response Deadline. Excluded Class Members (i.e., Non-Participating Class Members) will not receive Individual Class Payments but will preserve their rights to personally pursue wage and hour claims against Defendant.

   Class Members cannot opt-out of the PAGA portion of the Settlement. Class Members who exclude themselves from the Class Settlement (Non-Participating Class Members) remain eligible for Individual PAGA Payments and are required to give up their right to assert PAGA claims against Defendants based on the PAGA Period facts alleged in the Action.

7. The Proposed Settlement Will be Void if the Court Denies Final Approval. It is possible the Court will decline to grant Final Approval of the Settlement or decline to enter a Judgment. It is also possible the Court will enter a Judgment that is reversed on appeal. Plaintiffs and Defendants have agreed that, in either case, the Settlement will be void: Defendants will not pay any money and Class Members will not release any claims against Defendants.

8. Administrator. The Court has appointed a neutral company, Simpluris (the “Administrator”) to send this Notice, calculate and make payments, and process Class Members’ Requests for Exclusion. The Administrator will also decide Class Member Challenges over Workweeks, mail and re-mail settlement checks and tax forms, and perform other tasks necessary to administer the Settlement. The Administrator’s contact information is contained in Section 9 of this Notice.

9. Release by Participating Class Members. After the Judgment is final and Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless a Class Member opted out by validly excluding themselves from the Class Settlement, they cannot sue, continue to sue, or be part of any other lawsuit against Defendants or related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement.

   The Participating Class Members will be bound by the following release:

   • All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint and ascertained in the course of the Action including, e.g., failure to pay overtime wages at the correct rate; failure to pay double time wages at the correct rate; failure to pay overtime and/or double time wages by failing to include all applicable remuneration in calculating the regular rate of pay; failure to provide meal periods; failure to provide rest periods; failure to pay premium wages for missed meal and rest periods; failure to provide with accurate written wage statements; failure to pay wages due, negotiable and payable in cash on demand; failure to provide employment records for inspection; failure to provide with reporting time pay; failure to pay split shift payments; failure to pay sick time pay at the correct rate; failure to provide notice of paid sick time; failure to reimburse them with necessary business expenditures; and failure to pay all of their final wages following separation of employment in violation of Labor Code §§ 201, 202, 203, 204, 210, 212, 213, 215, 216, 218.6, 223, 225, 226, 226.6, 226.7, 226(a), 246, 354, 408, 432, 510, 512, 553, 1174, 1175, 1182.2, 1194, 1194.2, 1197, 1197.1, 1198, 1198.5, 2800 and 2802 as well as California Code of Regulations, Title 8 section 11050(5)(A) and 11050(4)(C) and Bus. & Prof. Code sections 17200 and 17203. Except as set forth in Section 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation or claims based on facts occurring outside the Class Period.

10. Release by Non-Participating Class Members Who Are Aggrieved Employees. After the Court’s judgment is final, and Defendants have paid the Gross Settlement (and separately paid the employer-side payroll taxes), all Aggrieved Employees will be barred from asserting PAGA claims against Defendants whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendants or their related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement.

    The Aggrieved Employees’ Releases for Non-Participating and Participating Class Members are as follows:

    • All Non-Participating Class Members and Participating Class Members who are Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the PAGA Period facts stated in the Operative Complaint, and the PAGA Notices and ascertained in the course of the Action including, e.g., failure to provide employment records, failure to pay overtime/double time, failure to provide meal and rest periods, failure to pay minimum wages, failure to keep accurate and provide itemized wage statements, failure to pay reporting time, failure to pay split shifts, failure to timely pay wages during employment, failure to pay wages on termination, failure to reimburse necessary business expenses and costs, failure to provide notice of paid sick time and accrual, Labor Code §§ 201, 202, 203, 204, 210, 212, 213, 223, 226, 226.7, 226(a), 432, 510, 512, 558(a), 1174, 1182.2, 1194, 1194.2, 1197, 1197.1, 1198, 1198.5, 2698, 2699, et. seq., 2800 and 2802 as well as California Code of Regulations, Title 8 section 11050(5)(A) and 11050(4)(C).

4. What are the important terms of the proposed Settlement?

1. Individual Class Payments. The Administrator will calculate Individual Class Payments by (a) dividing the Net Settlement Amount by the total number of Workweeks worked by all Participating Class Members, and (b) multiplying the result by the number of Workweeks worked by each individual Participating Class Member.

2. Individual PAGA Payments. The Administrator will calculate Individual PAGA Payments by (a) dividing the Gross Settlement Amount by the total number of PAGA Pay Periods worked by all Aggrieved Employees and (b) multiplying the result by the number of PAGA Period Pay Periods worked by each individual Aggrieved Employee.

3. Workweek/Pay Period Challenges. The number of Class Workweeks Class Members worked during the Class Period and the number of PAGA Pay Periods Class Members worked during the PAGA Period, as recorded in Defendants’ records, will be provided to Class Members in a Court ordered notice. Class Members have until April 20, 2026, to challenge the number of Workweeks and/or Pay Periods credited to them. Submit challenges by signing and sending a letter to the Administrator via mail, email or fax. See Question 9 for the Administrator’s contact information.

Class Members need to support their challenge by sending copies of pay stubs or other records. The Administrator will accept Defendants’ calculation of Workweeks and/or Pay Periods based on Defendants’ records as accurate unless copies of records containing contrary information are provided. Please send copies rather than originals because the documents will not be returned. The Administrator will resolve Workweek and/or Pay Period challenges based on submissions and on input from Class Counsel (who will advocate on behalf of Participating Class Members) and Defendants’ Counsel. The Administrator’s decision is final. Class Members can’t appeal or otherwise challenge its final decision.

5. How will I get paid?

1. Participating Class Members. The Administrator will send, by U.S. mail, a single check to every Participating Class Member (i.e., every Class Member who doesn’t opt-out) including those who also qualify as Aggrieved Employees. The single check will combine the Individual Class Payment and the Individual PAGA Payment.

2. Non-Participating Class Members Who are Aggrieved Employees. The Administrator will send, by U.S. mail, a single Individual PAGA Payment check to every Aggrieved Employee who opts out of the Class Settlement (i.e., every Non-Participating Class Member).

Settlement checks will be sent to Class Members’ latest address as available to the Administrator. In the event a Class Member has a change of address, be sure to notify the Administrator as soon as possible. See Question 9 for the Administrator’s contact information.

6. How do I opt-out of the class Settlement?

Submit a written and signed letter with the your name, present address, telephone number, and a simple statement that you do not want to participate in the Settlement. The Administrator will exclude you based on any writing communicating your request be excluded. Be sure to personally sign your request, identify the Action as Carter et. al. v. On Time Management & Staffing, et al., Los Angeles County Superior Court, Case No. 24PSCV00259, and include your identifying information (full name, address, telephone number, approximate dates of employment, and social security number for verification purposes). You must make the request yourself. If someone else makes the request for you, it will not be valid. The Administrator must be sent your request to be excluded by April 20, 2026, or it will be invalid. See Question 9 for the Administrator’s contact information.

7. How do I object to the Settlement?

Only Participating Class Members have the right to object to the Settlement. Before deciding whether to object, Class Members may wish to see what Plaintiffs and Defendants are asking the Court to approve. Any objection or challenge to the number of Class Workweeks or PAGA Pay Periods must be received by April 20, 2026. Sixteen court days before the Final Approval Hearing, Class Counsel and/or Plaintiffs will file in Court (1) a Motion for Final Approval that includes, among other things, the reasons why the proposed Settlement is fair, and (2) a Motion for Fees, Litigation Expenses and Service Award stating (i) the amount Class Counsel is requesting for attorneys’ fees and litigation expenses; and (ii) the amount Plaintiffs are requesting as a Class Representative Service Award.

You can view the copies of these documents on Important Documents page or the Court’s website https://www.lacourt.org. Also, upon reasonable request, Class Counsel (whose contact information is in Question 9) will send Class Members copies of these documents at no cost to them.

A Participating Class Member who disagrees with any aspect of the Agreement, the Motion for Final Approval and/or Motion for Fees, Litigation Expenses and Service Awards may wish to object, for example, that the proposed Settlement is unfair, or that the amounts requested by Class Counsel or Plaintiffs are too high or too low. The deadline for sending written objections to the Administrator is April 20, 2026. Be sure to tell the Administrator what you object to, why you object, and any facts that support your objection. Make sure to identify the Carter et. al. v. Ready Pac Foods, Inc., et al., Los Angeles County Superior Court, Case No. 24PSCV00259 and include your name, current address, telephone number, and approximate dates of employment for Defendants and sign the objection. See Question 9 for the Administrator’s contact information.

Alternatively, a Participating Class Member can object (or personally retain a lawyer to object at your own cost) by attending the Final Approval Hearing. You (or your attorney) should be ready to tell the Court what you object to, why you object, and any facts that support your objection. See Question 8 of this Notice (immediately below) for specifics regarding the Final Approval Hearing.

8. Can I attend the Final Approval Hearing?

Class Members can, but don’t have to, attend the Final Approval Hearing on July 17, 2026, in Department 12 of the Los Angeles Superior Court, Spring Street Courthouse, located at 312 North Spring Street, Los Angeles, CA 90012. At the Hearing, the judge will decide whether to grant Final Approval of the Settlement and how much of the Gross Settlement will be paid to Class Counsel, Plaintiffs, and the Administrator. The Court will invite comment from objectors, Class Counsel and Defense Counsel before making a decision. Class members can attend (or hire a lawyer to attend) either personally or virtually via LACourtConnect (https://www.lacourt.org/lacc). Check the Court’s website for the most current information.

It’s possible the Court will reschedule the Final Approval Hearing. Please check this website beforehand or contact Class Counsel to verify the date and time of the Final Approval Hearing.

9. How can I get more information?

The Agreement sets forth everything Defendants and Plaintiff have promised to do under the proposed Settlement. The easiest way to read the Agreement, the Judgment or any other Settlement documents is to view them, along with other case-related documents, on the Important Documents page.

Class Members can also telephone or send an email to Class Counsel or the Administrator using the contact information listed below, or consult the Superior Court website by going to https://www.lacourt.org/pages/lp/access-a-case/tp/find-case-information/cp/os-civil-case-access and entering the Case Number for the Action, Case No. 24PSCV00259. Class Members can also make an appointment to personally review court documents in the Clerk’s Office at the Spring Street Courthouse by calling (213) 633-6333.

Do not telephone the Superior Court to obtain information about the Settlement.

10. What if I lose my Settlement check?

If you lose or misplace your Settlement check before cashing it, the Administrator will replace it as long as you request a replacement before the void date on the face of the original check. If your check is already void you should consult the Unclaimed Property Fund through the California State Controller’s Office at https://www.sco.ca.gov/upd_msg.html for instructions on how to retrieve the funds

11. What if I change my address?

To receive your check, you should immediately notify the Administrator if you move or otherwise change your mailing address.