THIS IS A COURT-APPROVED NOTICE, NOT A SOLICITATION FROM A LAWYER. NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION LAWSUIT AGAINST “Cheeks,” “Top Hat,” “House of Babes,” “Private Dancer,” “Fantasyland West,” and “Sirens” Clubs, their owners and managers, Greg Flaig, the Buckeye Association of Club Executives, and The Owners Coalition To: All current and former dancers and/or entertainers who work or worked at Cheeks in West Carrollton, Ohio; Private Dancer in Columbus, Ohio; Top Hat in Mansfield, Ohio; House of Babes in Columbus, Ohio; Fantasyland West in Bucyrus, Ohio; or Sirens in Columbus, Ohio Re: Lawsuit against Cheeks, Top Hat, House of Babes, Private Dancer, Fantasyland West, and Sirens, their owners and managers, Greg Flaig, the Buckeye Association of Club Executives, and The Owners Coalition Case: Jessica Hogan, et al. v. Cleveland Ave. Restaurant, Inc., et al., Case No. 2:15-cv-2883 The United States District Court for the Southern District of Ohio, Eastern Division INTRODUCTION This is a court-approved Notice. It is not a solicitation from a lawyer. This Notice is to inform you about a proposed Settlement of a lawsuit that was filed as a class action by Plaintiffs Jessica Hogan and DeJha Valentine, and that was certified by the above Court, against Defendants Cheeks, Top Hat, House of Babes, Private Dancer, Fantasyland West, and Sirens, their owners and managers, Greg Flaig, the Buckeye Association of Club Executives (“BACE”), and The Owners Coalition (“OC”). The Plaintiffs and the Defendants are collectively referred to in this Notice as “the Parties.” In this lawsuit, the Plaintiffs have sought to recover from the Defendants an award of unpaid wages for dancers and/or entertainers (for ease of reference, they will simply be referred to as dancers) and other damages under federal and Ohio law. You are receiving this Notice because the Defendants’ records indicate that you work, or at some point between May 14, 2014 and June 16, 2025 worked, at one or more of the Defendant clubs and may be a member of the Class in this case. NATURE OF THE LAWSUIT This lawsuit was brought by Plaintiffs Jessica Hogan and DeJha Valentine. Ms. Hogan has danced at Sirens; Ms. Valentine has danced at Sirens and House of Babes. In the lawsuit, the Plaintiffs have sought to recover damages and secure other relief on behalf of themselves and others similarly situated. The Ohio strip clubs named as defendants in this case allegedly required their dancers to sign a “Lease Agreement” or some similar form of a contract in order to work at their clubs. The “Lease Agreement” allegedly was created by Defendant Greg Flaig. The Plaintiffs have challenged the legality of the “Lease Agreement” in this case. The Plaintiffs have alleged, among other things, that during some or all of the time period beginning May 14, 2014, the defendant clubs did not pay dancers any wages, purportedly based on the terms of the “Lease Agreement.” The Plaintiffs also have alleged that, instead of paying 1|Page dancers their rightful wages during this period, each club that is named as a Defendant charged dancers various unlawful fees, including “rent,” to work at the club, incorrectly claiming that the dancers were “tenants” who “leased space” at the club and that therefore the dancers were “independent contractors” rather than employees. The Plaintiffs have sought an award of unpaid wages for the hours dancers worked at these clubs, plus the recovery of all unlawful deductions, as well as additional damages under Ohio law and the Fair Labor Standards Act (“FLSA”). The Plaintiffs also have sought damages under Ohio common law for civil conspiracy and unjust enrichment, damages under federal and state antitrust laws for price fixing, and injunctive relief. The Defendants have denied, and continue to deny, most of these allegations and claim that they did not violate applicable laws. DESCRIPTION OF THE PROPOSED CLASS ACTION SETTLEMENT Subject to approval by the United States District Court for the Southern District of Ohio, the Parties have agreed to settle their dispute for monetary relief in the amount of $800,000.00 as well as specified non-monetary relief. The Plaintiffs have agreed to settle for this monetary and non-monetary relief on behalf of and for the benefit of a Class previously certified by the Court. In its previous order, the Court defined a Class consisting of all non-owner, non-employer exotic dancers who worked at any club named as defendants at any time from May 14, 2014 to the present (1) while such club (a) has used the Entertainer Tenant System created and disseminated by defendant Greg Flaig, or (b) has required its dancers to sign and abide by the Entertainer Tenant Space Lease Agreement created and disseminated by defendant Greg Flaig, or (c) has otherwise formally regarded its dancers as leasing space at such club as entertainers and required them to acknowledge the same, and (2) while such club did not pay any wages to its dancers. Under the proposed Settlement, dancers who entertained at one of the clubs listed above sometime between May 14, 2014 and June 16, 2025 would be eligible to make a claim for a share of the monetary relief (see “How to Make a Claim” section below) and to benefit from the non-monetary relief provided for in it, if the Court approves the Settlement. As non-monetary relief, the proposed Settlement provides as follows: A. Beginning 30 days after Final Approval of the Settlement, the Defendants will permanently cease using the Entertainer Tenant System, the Entertainer Tenant Space Lease Agreement, and any of the applications, attachments, and individual parts which accompany that Lease Agreement and will permanently cease imposing any “rent” charge on dancers at their respective clubs as previously charged under that Lease Agreement. B. Beginning 30 days after Final Approval of the Settlement, defendants Greg Flaig, BACE, and OC will permanently cease disseminating to Ohio strip clubs, club owners, club managers, or their agents or employees, or promoting or encouraging their use of, the Entertainer Tenant System, the Entertainer Tenant Space Lease Agreement, and any of the applications, attachments, and individual parts which accompany that Lease Agreement. C. Beginning 30 days after Final Approval of this Settlement, Defendants, to the extent they remain in the business of operating strip clubs, will allow dancers at their clubs to choose their classification as employees or independent contractors, or such Defendants can choose to classify all dancers as employees. Each such Defendant may make this choice independently. If a dancer at such club chooses to be classified as an employee, such Defendants at such club will comply with all state and federal laws pertaining to that status, including but not limited to employee wage and 2|Page hour laws, the payment of minimum wage, overtime, and relevant taxes. If a dancer at such club chooses to be classified as an independent contractor, such Defendants at such club will treat such dancer as a true independent contractor, as that status is defined under Ohio law. Defendants will not attempt to persuade dancers to choose to be an independent contractor rather than an employee. On December 1, 2026, the Court will hold a hearing on whether to approve the Settlement and on whether to approve the request of the Plaintiffs’ Attorneys for an award of attorney fees, for reimbursement of litigation expenses advanced by these attorneys, and for service awards for the two class representatives. (See section on “The Plaintiffs’ Attorneys” below). YOUR RIGHT TO OBJECT TO THE PROPOSED SETTLEMENT You have the right to object to the proposed settlement, if you so choose. Your objection must be in writing and must be received by the plaintiffs’ Attorneys (see their addresses in the section on “The Plaintiffs’ Attorneys” below) no later than October 20, 2026, in order to be considered by the Court. The objection must include a written statement (1) objecting to the Settlement, (2) setting forth the specific reasons for the objection, including any legal or evidentiary support for the objection, (3) stating whether the objector intends to appear and object to the Settlement at the Final Approval Hearing, (4) a list of all cases in which the objector and/or her/his counsel objected to a Settlement, and (5) containing the objector’s name, address, and telephone number. The objector must sign and date the objection. An individual waives her or his right to object and/or appear at the Final Approval Hearing if she or he fails to comply with these requirements. If you submit an objection to the proposed settlement, you may but do not have to appear at the hearing before the Court on December 1, 2026. You do not have to submit an objection to the Settlement in order to submit a claim form for compensation under it. WHAT CLASS MEMBERS WOULD RELEASE UNDER THE PROPOSED SETTLEMENT Unless you exclude yourself from this lawsuit as described below, you will be bound by the judgment in this case. This means that, if the court approves the proposed Settlement, as a Class Member remaining in this case you would automatically release certain causes of action against the Released Parties as provided for in the proposed Settlement. The proposed Settlement defines the “Released Parties” as “the Defendants and all related entities, along with all their predecessors, successors, parents, subsidiaries, franchisors, insurers, affiliates, owners, members, stockholders, officers, directors, employees, partners, shareholders, agents, legal representatives, affiliates, insurance carriers and all persons acting by, through, under, or in concert with them.” Under the proposed Settlement, each class member automatically would release the released parties from all causes of action that were raised in the operative Complaint or that could have been raised based on the facts in it, including but not limited to claims for unpaid wages, misappropriated tips, unlawful wage deductions, antitrust, civil conspiracy, unjust enrichment, liquidated damages, treble damages, attorneys’ fees and costs, and interest, except that class members’ Fair Labor Standards Act (“FLSA”) claims are excluded from the automatic release described above. In addition to the automatically released claims described above, class members who fill out and submit valid claim forms as described below would also release the FLSA claims that were raised on their behalf in the operative Complaint or that could have been raised on their behalf based on the facts in that Complaint, including but not limited to claims for unpaid wages, misappropriated tips, unlawful wage deductions, liquidated damages, treble damages, attorneys’ fees and costs, and interest. 3|Page HOW TO MAKE A CLAIM FOR COMPENSATION UNDER THE PROPOSED CLASS ACTION SETTLEMENT, IF IT IS APPROVED If you worked as an entertainer at one of the clubs listed sometime between May 14, 2014 and June 16, 2025, you may make a claim for compensation under the proposed class action settlement, if the Court approves it. To do so, you must complete the required claim form in one of the following ways no later than October 20, 2026, which is 90 days from the date of this Notice: 1. Online Submission | Complete and submit an online claim form, which you can access at www.OhioStripClubCase.com, by clicking on: GO TO STRIP CLUB CASE ONLINE CLAIM FORM THAT ALLOWS ELECTRONIC SIGNATURE 2. Submission by U.S Mail | Print off the claim form that appears at the end of this Notice, complete it, and mail it to the Claims Administrator at: Hogan v. Cleveland Ave. Restaurant c/o Atticus Administration PO Box 64053 St. Paul, MN 55164 If your claim form is not received by the Administrator on or before October 20, 2026, which is 90 days from the date of this Notice, you will be ineligible for compensation under the proposed class action settlement. Regardless of whether you submit a timely claim form, you will be entitled to take advantage of the non-monetary relief provided by the Settlement, if it is approved by the Court. (See section on “Description of the Proposed Class Action Settlement” above.) HOW TO COMPLETELY EXCLUDE YOURSELF FROM THIS LAWSUIT If you wish to completely exclude yourself from this lawsuit and receive no money from it or from the proposed Settlement, you must submit an exclusion letter to the Plaintiffs’ Attorneys by U.S. mail, email, or fax, as follows: • By Mail to: BILLER & KIMBLE, LLC, Re: Hogan v. Cleveland Ave. Restaurant, 8044 Montgomery Rd., Ste. 515, Cincinnati, OH 45236 • By email to: info@billerkimble.com, Re: Hogan v. Cleveland Ave. Restaurant • By fax to: (614) 340-4620 To be valid, the letter must be received by October 20, 2026, which is 90 days from the date of this Notice, and must contain the following statement or a substantially similar statement: I wish to opt-out of the lawsuit Jessica Hogan v. Cleveland Ave. Restaurant, Inc., et al., Case No. 2:15-cv-2883. I understand that by requesting to opt-out of the lawsuit, I will receive no money from the Settlement. I understand that I may bring my own lawsuit for the same claims in this lawsuit. I understand that, in my own lawsuit, I might receive a different result—good or bad—from that obtained in this lawsuit. 4|Page THE PLAINTIFFS’ ATTORNEYS AND THEIR REQUEST FOR AN AWARD OF ATTORNEY FEES, REIMBURSEMENT OF LITIGATION EXPENSES, AND SERVICE AWARDS FOR THE TWO CLASS REPRESENTATIVES The Plaintiffs and the Class Members are represented by the following law firms and attorneys: Paul M. De Marco Andrew R. Biller MARKOVITS, STOCK & DEMARCO, LLC BILLER & KIMBLE, LLC 119 East Court Street, Suite 530 4200 Regent Street, Suite 200 Cincinnati, Ohio 45202 Columbus, OH 43219 Tel.: (513) 651-3700 Tel.: (513) 202-0710 pdemarco@msdlegal.com abiller@billerkimble.com Website: www.msdlegal.com Website: www.billerkimble.com The U.S. District Court appointed these law firms to represent the employees. You do not need to separately pay fees or expenses to the Plaintiffs’ Attorneys for this representation. Instead, the Plaintiffs’ Attorneys are asking the Court to approve an award of one-third of the Settlement Amount as fees, plus reimbursement of the litigation expenses that they have advanced in this case, as well as a $5,000 service award for each of the Class Representatives, Ms. Hogan and Ms. Valentine. You may contact the Plaintiffs’ Attorneys at any time to obtain more information about the lawsuit and the proposed settlement. You may also obtain your own counsel at your own expense. THE DEFENDANTS CANNOT RETALIATE AGAINST YOU FOR PARTICIPATING IN THIS LAWSUIT. The law strictly forbids any employer from retaliating against an employee for being involved in or making a claim in a lawsuit. This includes a prohibition against firing you, docking your pay, changing your hours, etc. If you experience retaliation, report it immediately to the Plaintiffs’ Attorneys. 5|Page