SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF CLARK
NOTICE OF CLASS ACTION SETTLEMENT
You may be eligible for a class action settlement payment in relation to your employment with Big Al’s, Inc.
Clark County Superior Court authorized this notice. You are not being sued. This is not a solicitation from an
attorney. Please read carefully.
• Former employee Adele Lazova-Fast (“Plaintiff”) filed a lawsuit against Big Al’s, Inc. (“Defendant”) on
behalf of herself and a class of similarly situated current and former employees for alleged violations of
the Washington Noncompetition Covenants Act, chapter 49.62 RCW. The lawsuit, Lazova-Fast v. Big Al’s,
Inc., is currently pending in Clark County Superior Court as Case Number 25-2-01504-06 (the “Lawsuit”).
The Court has not made any determinations regarding the merits of the Lawsuit, nor has it decided whether
Defendant violated Washington law.
• The Parties have reached a proposed settlement which includes a total payment by Defendant of
$450,000.00 (“Common Fund”). On May 22, 2026, the Court issued an order preliminarily approving the
settlement and authorizing the Settlement Administrator, Simpluris, Inc. (“Settlement Administrator”), to
issue this Notice.
• You are receiving this Notice because Defendant’s records indicate you are a settlement class member.
“Settlement Class Members” are defined as “Plaintiff and all current and former employees of Big Al’s,
Inc. who worked in Washington and earned less than twice the applicable state minimum hourly wage
from January 1, 2020, through May 22, 2026.”
• The Court still has to decide whether to approve the settlement. No settlement benefits or payments will
be provided unless the Court approves the settlement and it becomes final.
• Read this Notice carefully. Your legal rights are affected regardless of whether you act or not. For more
information, visit www.BAIncSettlement.com.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
To receive your settlement payment, you must ensure the Settlement Administrator has
PROVIDE/UPDATE VALID your updated and valid mailing address. Please contact the Settlement Administrator
MAILING ADDRESS to provide your valid mailing address or submit the Address Form enclosed with
this Notice.
If you request to be excluded, you will no longer be in the Settlement Class and will not
EXCLUDE YOURSELF FROM receive a settlement payment. This is the only option that allows you to keep any right to
THE SETTLEMENT sue Defendant about the same legal claims in this Lawsuit. The deadline to request
exclusion from the settlement is August 24, 2026.
Write to the Court explaining why you do not agree with the settlement. You must not
OBJECT TO THE
exclude yourself from the settlement if you wish to object. The deadline to object is
SETTLEMENT
August 24, 2026.
ATTEND THE FINAL You may ask the Court for permission for you or your attorney to speak about your
APPROVAL HEARING objection at the Final Approval Hearing. The Final Approval Hearing will be held before
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Notice of Class Action Settlement
Judge Gregory M. Gonzales on September 25, 2026, at 9:00 A.M. To attend remotely
via Zoom, you may use the following link:
Zoom Link: https://clark-wa-
gov.zoom.us/j/86788207460?pwd=vBwpKbKCDQcsqt3WYTdDmpX8HOylUv.1
BASIC INFORMATION
1. What is this Notice and why should I read it?
The Court authorized this Notice to inform you about a proposed settlement. You have legal rights and options that you
may act on before the Court decides whether to approve the settlement. If approved, you are eligible to receive a payment
as part of the settlement. This Notice explains the Lawsuit, the Settlement Agreement, and your legal rights.
2. What is a class action lawsuit?
A class action is a lawsuit in which one or more plaintiffs sue on behalf of a group of people who have similar claims.
Together, this group is called a “Settlement Class” and consists of “Settlement Class Members.” In a class action, the court
resolves the issues for all class members, except those who exclude themselves from the class.
3. What is this lawsuit about?
Plaintiff claims that Defendant violated Washington law, RCW 49.62.070, when it bound employees to an outside
employment policy. Defendant denies that it is or can be held liable for the claims made in the Lawsuit. More information
about the Lawsuit can be found in the “Important Documents” section of the Settlement Website at
www.BAIncSettlement.com.
4. Why is there a settlement?
The Court has not decided who should win this case. Instead, the parties agreed to settlement. That way, they can avoid the
uncertainty, risks, and expense of ongoing litigation, and Settlement Class Members will get compensation now rather than
years later—if ever. Plaintiff and Class Counsel, attorneys for the Settlement Class Members, agree the settlement is in the
best interests of the Settlement Class Members. The settlement is not an admission of wrongdoing by Defendant.
5. How do I know if I am in the Settlement Class?
Defendant’s records show you are part of the Settlement Class because you worked for Defendant between January 1, 2020,
and May 22, 2026, and earned less than twice the applicable state minimum hourly wage. You can contact the Settlement
Administrator by calling toll-free at 1-888-369-3780, emailing [email protected], or visiting the Settlement
Website at www.BAIncSettlement.com.
THE SETTLEMENT BENEFITS
6. What does the settlement provide?
All Settlement Class Members who do not exclude themselves from the settlement are eligible to receive an equal share of
the Class Fund. Settlement payments will be characterized as non-wage damages (1099).
7. How do I receive a payment?
To ensure you receive your payment, you must confirm the Settlement Administrator has your current mailing
address. You must also contact the Settlement Administrator if your address or phone number changes at any time.
If the Settlement Administrator does not have your current mailing address, you may not receive your settlement payment.
To provide and/or update your current mailing address, you must contact the Settlement Administrator (contact information
below), or you may submit the Address Form that accompanies this Notice. The Address Form can be submitted to the
Settlement Administrator by mail or email at:
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Notice of Class Action Settlement
Lazova-Fast v. Big Al’s, Inc.
c/o Simpluris, Inc.
P.O. Box 26170, Santa Ana, CA 92799
(888) 369-3780
[email protected]
8. When will I get my payment?
The hearing to consider the fairness of the settlement is scheduled for September 25, 2026, at 9:00 A.M. If the Court
approves the settlement, eligible Settlement Class Members who did not exclude themselves from the settlement will be
sent a settlement payment after all appeals and other reviews, if any, are complete. Please be patient. All settlement payments
will expire and become void 180 days after the date of issuance.
9. Will Defendant retaliate against me if I participate in the settlement?
No. Defendant fully supports the settlement and will not retaliate in any way against any Settlement Class Member for
participating in the settlement. Your decision to participate, not participate, or object to the settlement will not affect your
employment with Defendant or Defendant’s treatment of you as a current or former employee.
THE ATTORNEYS REPRESENTING YOU
10. Do I have an attorney in this case?
Yes, the Court appointed Timothy W. Emery, Patrick B. Reddy, and Paul Cipriani of Emery Reddy, PC as Class Counsel
to represent the Settlement Class. Their contact information is:
Emery Reddy, PC
600 Stewart Street, Suite 1100
Seattle, WA 98101
Phone: (206) 442-9106
Should I get my own attorney? You don’t need to hire your own attorney because Class Counsel are working on your
behalf. These attorneys and their firm are experienced in handling similar cases. You will not be charged for these attorneys.
You can ask your own attorney to appear in Court for you, at your own cost, if you want someone other than Class Counsel
to represent you.
11. How will Class Counsel and the Class Representative be paid?
Class Counsel will ask the Court to approve, and Defendant agrees not to oppose, an award of attorneys’ fees in the amount
of $149,999.00, plus costs and expenses of $5,000.00, to be paid from the Settlement Fund. Class Counsel will also request
a service award for Plaintiff in the amount of $20,000.00, to be paid from the Settlement Fund. The Court will determine
the proper amount of any attorneys’ fees, costs, and expenses to award Class Counsel and the proper amount of any service
award to Plaintiff. The Court may award less than the amounts requested. Whether the settlement will be finally approved
does not depend on whether or how much the Court awards in attorneys’ fees, costs, and expenses or service award.
YOUR RIGHTS AND OPTIONS
12. What claims do I give up by participating in this settlement?
If the Court approves the settlement, the Court will enter a final judgment dismissing the Lawsuit “with prejudice.” This
means that the claims in the Lawsuit will be permanently dismissed. Specifically, Defendant will be “released” from claims
pursuant to Paragraph 18 of the Settlement Agreement, which states:
Upon final approval of this Settlement Agreement by the Court, each Settlement Class Member who does
not submit a timely request for exclusion in accordance with the procedures set forth herein will release,
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Notice of Class Action Settlement
waive, and forever discharge: (i) Defendant, and its parents, subsidiaries, affiliates, related
companies/corporations and/or partnerships (defined as a company/corporation and/or partnership that are,
directly or indirectly, under common control with Defendant or any of its parents and/or affiliates),
investors, owners, joint ventures, joint employers, alter-egos, divisions, insurers, reinsurers, insurance
policies, and benefit plans, or any other entity with an interest in or obligation regarding Defendant’s
liabilities, (ii) each of the past, present, and future officers, directors, agents, employees, equity holders
(shareholders, holders of membership interests, etc.), representatives, agents, administrators, fiduciaries and
attorneys of the entities and plans described in this sentence; and (iii) the predecessors, successors,
transferees, and assigns of each of the persons and entities described in this sentence (the “Released
Parties”) from all claims that arose during the Settlement Class Period that were and could have been
asserted against the Released Parties by Plaintiff and Settlement Class Members in the Complaint (the
“Released Class Claims”).
By being part of the settlement, Settlement Class Members agree that they cannot sue or seek recovery against Defendant
or other Released Parties as described in the Settlement Agreement for any released claims. Participating in the settlement
does not, however, waive claims outside the release. Any potential Settlement Class Member who does not request exclusion
by August 24, 2026, will be a Settlement Class Member and will be considered to have accepted the above release and to
have waived any and all of the released claims against the Released Parties. Any potential Settlement Class Member who
requests exclusion by the applicable deadline is not a Settlement Class Member, will not be subject to the release, and will
not receive any payment.
13. What happens if I do nothing?
If you do nothing and the Court approves the settlement, you will still be in the Settlement Class, receive a payment, and be
bound by all orders and judgments of the Court, the Settlement Agreement, and its included release. Unless you exclude
yourself, you won’t be able to file a lawsuit or be part of any other lawsuit against Defendant for the claims or legal issues
resolved in this settlement.
14. What happens if I request to be excluded?
If you submit a timely, valid request for exclusion from the settlement, you will not be in the Settlement Class and will not
receive a settlement payment. However, you will not release claims against Defendant, and you will not be legally bound
by the Court’s judgments in this Lawsuit.
15. How do I request to be excluded?
To request to be excluded from the settlement, you must send a letter, postmarked no later than August 24, 2026, to the
Settlement Administrator at the following address:
Lazova-Fast v. Big Al’s, Inc.
c/o Simpluris, Inc.
P.O. Box 26170, Santa Ana, CA 92799
To be considered valid, a request for exclusion must include: (i) your full name; (ii) your address; (iii) a statement that you
wish to be excluded from the settlement; and (iv) your (or your attorney’s) signature and date signed. You cannot exclude
yourself by phone or email. Each individual who wants to be excluded from the settlement must submit his or her own
request for exclusion. Group requests for exclusion are not permitted.
16. If I don’t exclude myself, can I sue Defendant for the same thing later?
No. Unless you exclude yourself, you give up any right to sue Defendant for the claims being resolved by this settlement
even if you do nothing.
17. If I exclude myself, can I get anything from this settlement?
No. If you exclude yourself, you will not receive a settlement payment.
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Notice of Class Action Settlement
18. How do I object to the settlement?
If you do not exclude yourself from the Settlement Class, you can object to the settlement if you disagree with any part of
it. You can give reasons why you think the Court should deny approval of the settlement by filing an objection. To object,
you must file written notice with the Court stating that you object to the settlement in Lazova-Fast v. Big Al’s, Inc., no
later than August 24, 2026. Your objection must be filed with the Court, which you can do by mailing your objection and
any supporting documents to Clark County Superior Court at the following address:
Clark County Superior Court
Clark County Clerk
PO Box 5000
Vancouver, WA 98666
If you are represented by an attorney, the attorney may file your objection through the Court’s e-filing system. To be valid,
your objection must be in writing and include: (i) your full name, address, telephone number, and e-mail address; (ii) the
case name and number; (iii) the reasons why you object to the settlement; (iv) the name and address of your attorney, if you
have retained one; (v) a statement confirming whether you and/or your attorney intend to personally appear at the Final
Approval Hearing; (vi) a list, by case name, court, and docket number, of all other cases in which you (directly or through
an attorney) have filed an objection to any proposed class action settlement within the last three years; (vii) a list, by case
name, court, and docket number, of all other cases in which your attorney (on behalf of any person or entity) has filed an
objection to any proposed class action settlement within the last three years; and (viii) your (or your attorney’s) signature
and date signed.
In addition to filing your objection with the Court, you must also mail copies of your objection and any supporting
documents to both Class Counsel and Defendant’s attorneys at the addresses listed below, postmarked no later than August
24, 2026:
Class Counsel Defendant’s Counsel
Timothy W. Emery Darren A. Feider
Patrick B. Reddy Julian M. Cano
Paul Cipriani Sebris Busto James
Emery Reddy, PC 15375 SE 30th Place, Suite 310
600 Stewart Street, Suite 1100 Bellevue, WA 98007
Seattle, WA 98101
19. What’s the difference between objecting and excluding myself from the settlement?
Objecting simply means telling the Court that you don’t like something about the settlement. You can object only if you
stay in the Settlement Class. Excluding yourself from the Settlement Class is telling the Court that you don’t want to be part
of the Settlement Class. If you exclude yourself, you have no basis to object, because the case no longer affects you.
THE COURT’S FINAL APPROVAL HEARING
20. When and where will the Court hold a hearing on the fairness of the settlement?
The Court will hold the Final Approval Hearing before Judge Gregory M. Gonzales on September 25, 2026, at 9:00 A.M.
in Clark County Superior Court, 1200 Franklin St., Vancouver, WA 98660. To attend remotely via Zoom, you may use the
following link:
Zoom Link: https://clark-wa-gov.zoom.us/j/86788207460?pwd=vBwpKbKCDQcsqt3WYTdDmpX8HOylUv.1
The purpose of the hearing is for the Court to determine whether the settlement is fair, reasonable, adequate, and in the best
interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness
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Notice of Class Action Settlement
of the proposed settlement, including those related to the amount requested by Class Counsel for attorneys’ fees, costs, and
expenses and the service award for Plaintiff.
Note: The date and time of the Final Approval Hearing are subject to change by court order. Any changes will be posted at
the Settlement Website, www.BAIncSettlement.com, or through the Court’s publicly available docket. You should
check the Settlement Website to confirm the date and time have not been changed.
21. Do I have to come to the hearing?
No. Class Counsel will answer any questions the Court may have, but you are welcome to attend the hearing at your own
expense. If you send an objection, you don’t have to come to the hearing to talk about it. As long as your written objection
was filed or mailed on time and meets the other criteria described in the settlement, the Court will consider it. You may also
hire an attorney to attend on your behalf at your own expense, but you don’t have to.
22. May I speak at the hearing?
Yes. If you do not exclude yourself from the Settlement Class, you may ask the Court for permission to speak at the Final
Approval Hearing concerning any part of the proposed settlement.
GETTING MORE INFORMATION
23. Where can I get additional information?
This Notice summarizes the proposed settlement. More details are in the Settlement Agreement, which is available at
www.BAIncSettlement.com.
You may contact the Settlement Administrator by phone, email, or in writing at:
Lazova-Fast v. Big Al’s, Inc.
c/o Simpluris, Inc.
P.O. Box 26170, Santa Ana, CA 92799
(888) 369-3780
[email protected]
DO NOT CALL THE COURT, THE CLERK OF THE COURT, THE JUDGE, OR DEFENDANT WITH
QUESTIONS ABOUT THE SETTLEMENT OR NOTICE PROCESS.
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Notice of Class Action Settlement
