COURT APPROVED NOTICE OF CLASS ACTION SETTLEMENT AND
HEARING DATE FOR FINAL COURT APPROVAL
Griselda Dunia Bucio et al. v. FN Logistics, LLC
Los Angeles Superior Court Case No. 22STCV26948
The Superior Court for the State of California authorized this Notice. Read it carefully!
It’s not junk mail, spam, an advertisement, or solicitation by a lawyer. You are not being sued.
You may be eligible to receive money from an employee class action lawsuit (the “Action”) against FN
Logistics, LLC (“FNL”) for alleged wage and hour violations. The Action is being pursued by several persons
formerly employed by FNL or its predecessor or formerly placed to work at FNL or its predecessor by staffing
agencies. These named persons suing in particular are Griselda Dunia Bucio, Mercy Campos, Maria Escobedo
Lugo, and Kirkland Omega Slaton (“Plaintiffs”). Plaintiffs seek payment of back wages, penalties, and other
relief for a “Settlement Class” consisting of all current and former hourly, non-exempt employees who worked
for FNL or its predecessor FN Logistics, Inc. in California at any time from January 13, 2019, through December
31, 2024 (the “Class Period”), as well as any and all temporary employees who worked for Defendant or its
predecessor at any of their California locations during the Class Period and who were hired or placed through any
temporary or staffing agencies. The Settlement Class includes, but is not limited to, temporary workers from the
following temporary or staffing agencies: Adecco, Bluecrew, Personal HR, Randstad, Next Level Staffing, IWC,
Compliant Care Staffing, Driven Talent, and Eastridge. These persons are collective the “Class Members.”
Plaintiffs also seek penalties under the California Private Attorney General Act (“PAGA”) for all the previously
described persons who worked at FNL or its predecessor any time from October 2, 2021, through December 31,
2024 (the “PAGA Period”). The persons described in the preceding sentence are the “PAGA Members.”
The proposed Settlement has two main parts: (1) a class settlement requiring FNL to fund Individual Class
Payments, and (2) a PAGA settlement requiring FNL to fund Individual PAGA Payments and pay penalties to
the California Labor and Workforce Development Agency (“LWDA”).
Based on the records of FNL or the staffing agencies, your Individual Class Payment is estimated to
be $«MERGED_Class_EstSettAmnt_CALC» (less withholding) and your Individual PAGA Payment is
estimated to be $«MERGED_PAGA_EstSettAmnt_CALC». The actual amount you may receive likely will
be different and will depend on a number of factors. (If no amount is stated for your Individual PAGA Payment,
then according to the records of FNL and the staffing agencies you are not eligible for an Individual PAGA
Payment under the Settlement because you didn’t work during the PAGA Period.)
The above estimates are based on the records of FNL or staffing agencies showing that you worked
«MERGED_WW_CALC» workweeks during the Class Period and you worked
«MERGED_PAGA_PayPeriods_CALC» pay periods during the PAGA Period. If you believe that you
worked more during either period, you can submit a challenge by the deadline date. See Section 4 of this Notice.
The Court has already preliminarily approved the proposed Settlement and approved this Notice. The
Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not
act. Read this Notice carefully. You will be deemed to have carefully read and understood it. At the Final
Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the
Settlement will be paid to Plaintiffs and Plaintiffs’ attorneys (“Class Counsel”). The Court will also decide
whether to enter a judgment that requires FNL to make payments under the Settlement and requires Class
Members and PAGA Members to give up their rights to assert certain claims against FNL and related parties.
If you worked for FNL or its predecessor during the Class Period and/or the PAGA Period, you have two
basic options under the Settlement:
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(1) Do Nothing. You don’t have to do anything to participate in the proposed Settlement and be
eligible for an Individual Class Payment and/or an Individual PAGA Payment. As a Participating
Class Member, though, you will give up your right to assert Class Period wage and other claims
(as described below) and PAGA Period penalty claims against FN Logistics, LLC and related
parties.
(2) Opt-Out of the Class Settlement. You can exclude yourself from the Class Settlement (opt-out)
by submitting the written Request for Exclusion or otherwise notifying the Settlement
Administrator in writing. If you opt-out of the Settlement, you will not receive an Individual Class
Payment. You will, however, preserve your right to personally pursue Class Period wage claims
against FNL and, if you are a PAGA Member, remain eligible for an Individual PAGA Payment.
You cannot opt-out of the PAGA portion of the proposed Settlement.
FNL will not retaliate against you for any actions you take with respect to the proposed Settlement.
SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
You Don’t Have to Do If you do nothing, you will be a Participating Class Member, eligible for an
Anything to Participate in Individual Class Payment and an Individual PAGA Payment (if any). In
the Settlement exchange, you will give up your right to assert the claims against FNL that are
covered by this Settlement (Released Claims, as defined below).
You Can Opt-out of the If you don’t want to fully participate in the proposed Settlement, you can opt-out
Class Settlement but not of the Class Settlement by sending the Settlement Administrator a written Request
the PAGA Settlement for Exclusion to opt out of the Settlement. Once you opt out, you will no longer
be eligible for an Individual Class Payment. Persons sending a valid Request for
The Opt-out Deadline is Exclusion cannot object to any portion of the proposed Settlement. See Section 6
October 26, 2026. of this Notice.
You cannot opt-out of the PAGA portion of the proposed Settlement. FNL must
pay Individual PAGA Payments to all PAGA Members and all PAGA Members
must give up their rights to pursue PAGA Released Claims (defined below).
Participating Class All Class Members who do not opt-out by filing Requests for Exclusion
Members Can Object to (“Participating Class Members”) can object to any aspect of the proposed
the Class Settlement butSettlement. The Court’s decision whether to finally approve the Settlement will
not the PAGA Settlement 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
Written Objections Must for any payments to Class Counsel or Plaintiffs, but every dollar paid to Class
be Submitted by October Counsel and Plaintiffs reduces the overall amount paid to Participating Class
26, 2026 Members. You can object to the amounts requested by Class Counsel or Plaintiffs
if you think they are unreasonable. See Section 7 of this Notice.
You Can Participate in the The Court’s Final Approval Hearing is scheduled to take place on December 1,
December 1, 2026 Final 2026. You don’t have to attend but you do have the right to appear (or hire an
Approval Hearing attorney to appear on your behalf at your own cost), in person, by telephone or by
using the Court’s virtual appearance platform. Participating Class Members can
verbally object to the Settlement at the Final Approval Hearing. See Section 8 of
this Notice.
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You Can Challenge the The amount of your Individual Class Payment and PAGA Payment (if any)
Calculation of Your depend on how many workweeks you worked at least one day during the Class
Workweeks/Pay Periods Period and how many pay periods you worked at least one day during the PAGA
Period, respectively. Your applicable numbers of workweeks and pay periods
Written Challenges Must according to the records of FNL or the staffing agencies is stated on the first page
be Submitted by October of this Notice. If you disagree with either of these numbers, you must challenge
26, 2026 it by October 26, 2026. See Section 4 of this Notice.
1. WHAT IS THE ACTION ABOUT?
Plaintiffs are several persons formerly employed by FNL or its predecessor or formerly placed to work at FNL or
its predecessor by staffing agencies. The Action accuses FNL and/or its staffing agencies of violating California
laws by failing to pay all overtime wages; failing to pay all overtime wages at required rates; failing to pay
minimum wages; failing to timely pay wages during work or upon termination; failing to reimburse expenses;
failing to provide required meal periods or rest breaks; failing to provide accurate itemized wage statements;
failing to provide sick days and sick pay; failing to provide suitable seating; and failing to maintain suitable
temperatures. 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”). Plaintiff is represented by
attorneys in the Action: Joseph Lavi and Vincent Granberry of Lavi & Ebrahimian, LLP; Marcus Bradley, Kiley
Grombacher, and Lirit King of Bradley/Grombacher, LLP; Emil Davtyan, David Yeremian, David Keledjian, and
David Arakelyan of D.Law, Inc.; Michael Nourmand and James A. De Sario of The Nourmand Law Firm, APC
(collectively, “Class Counsel”)
FNL strongly denies 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 FNL or Plaintiffs are correct on the merits. In the meantime,
Plaintiffs and FNL hired a retired judge in an effort to resolve their disputes by settling rather than continuing the
expensive and time-consuming process of litigation. The negotiations were successful. Plaintiffs and FNL have
negotiated and signed a written Settlement Agreement 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, FNL does 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)
FNL has 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
PAGA Members. The Court preliminarily approved the proposed Settlement as fair, reasonable and adequate,
authorized this Notice, and scheduled a hearing to determine Final Approval.
3. WHAT ARE THE IMPORTANT TERMS OF THE PROPOSED SETTLEMENT?
1. FNL Will Pay Five Million Five Hundred Sixty-Five Thousand Dollars and Zero Cents ($5,565,000.00)
as the Gross Settlement Amount. FNL has agreed to deposit the Gross Settlement Amount into an account
controlled by the Settlement Administrator of the Settlement. The Settlement Administrator will use the
Gross Settlement Amount to pay the Individual Class Payments, Individual PAGA Payments, Class
Representative Enhancement Payments, Class Counsel’s attorney’s fees and expenses, the Settlement
Administrator’s expenses, and penalties to be paid to the California Labor and Workforce Development
Agency (“LWDA”). Assuming the Court grants Final Approval, FNL will fund the Gross Settlement not
more than thirty (30) days after the Judgment entered by the Court become final. The Judgment will be
final after expiration of the time for appealing the Judgment, or a later date if the Judgment is appealed.
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2. Court Approved Deductions from Gross Settlement Amount. At the Final Approval Hearing, Plaintiff
and/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement
Amount, the amounts of which will be decided by the Court at the Final Approval Hearing:
A. Up to One Million Nine Hundred Forty-Seven Thousand Seven Hundred Fifty Dollars and No
Cents ($1,947,750.00) (35% of the Gross Settlement Amount) to Class Counsel for attorneys’ fees
and up to Fifty-Two Thousand Two Hundred Fifty Dollars and No Cents ($52,250.00) for their
litigation expenses. To date, Class Counsel have worked and incurred expenses on the Action
without payment.
B. Up to Ten Thousand Dollars and No Cents ($10,000.00) to each Plaintiff as a Class Representative
Enhancement Payment for filing the Action, working with Class Counsel and representing the
Settlement Class. These are the only amounts Plaintiffs will receive other than each Plaintiff’s
Individual Class Payment and any Individual PAGA Payment.
C. Up to Thirty-Two Thousand Dollars and No Cents ($32,000.00) to the Settlement Administrator
for services administering the Settlement.
D. Up to Two Hundred Thousand Dollars and No Cents ($200,000.00) for PAGA Penalties, allocated
75% to the LWDA and 25% in Individual PAGA Payments to the PAGA Members based on the
pay periods they worked during the PAGA Period.
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 Settlement Administrator will distribute the rest of the Gross Settlement Amount (the
“Net Settlement Amount”) by making Individual Class Payments to Participating Class Members based
on their workweeks during the class period.
4. Taxes Owed on Payments to Class Members. Plaintiffs and FNL are asking the Court to approve an
allocation of 20% of each Individual Class Payment to taxable wages (“Wage Portion”) and 80% to
interest and penalties (“Non-Wage Portion”). The Wage Portion is subject to withholdings and will be
reported on IRS W-2 Forms. FNL will separately pay employer payroll taxes it owes on the Wage Portion.
The Individual PAGA Payments are counted as penalties rather than wages for tax purposes. The
Settlement Administrator will report the Individual PAGA Payments and the Non-Wage Portions of the
Individual Class Payments on IRS 1099 Forms.
Although Plaintiffs and FNL have agreed to these allocations, neither side is giving you any advice on
whether your payments are taxable or how much you might owe in taxes. You are responsible for paying
all taxes (including penalties and interest on back taxes) on any payments received from the proposed
Settlement. You should consult a tax advisor if you have 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). If you don’t
cash it by the void date, your check will be automatically cancelled, and the monies will be deposited with
the California Controller’s Unclaimed Property Fund in your name.
If the monies represented by your check is sent to the Controller’s Unclaimed Property Fund, you should
consult the rules of the Fund for instructions on how to retrieve your money.
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6. Requests for Exclusion from the Class Settlement (Opt-Outs). You will be treated as a Participating Class
Member, participating fully in the Class Settlement, unless you notify the Settlement Administrator in
writing, not later than October 26, 2026, that you wish to opt-out. The easiest way to notify the Settlement
Administrator is to send a written and signed Request for Exclusion by the October 26, 2026 Response
Deadline. The Request for Exclusion must be a letter or post card that: (1) contains the name, address,
telephone number and the last four digits of the Social Security number of the Class Member; (2) contains
a statement that the Class Member wishes to be excluded from the Settlement Class; (3) is signed by the
Class Member; and (4) is postmarked by October 26, 2026 and mailed to the Settlement Administrator at
the address specified in this Notice. Excluded Settlement 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 FNL, subject to its defenses.
You cannot opt-out of the PAGA portion of the Settlement. Class Members who exclude themselves from
the Class Settlement remain eligible for Individual PAGA Payments and are required to give up their right
to assert PAGA claims against the Released Parties, as described in paragraph 9 below.
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 enter a Judgment. It is also possible the Court
will enter a Judgment that is reversed on appeal or that the Settlement does not become final for other
reasons. Plaintiffs and FNL have agreed that in such cases, the Settlement will be void: FNL will not pay
any money and Class Members will not release any claims
8. Settlement Administrator. The Court has appointed a neutral company, Simpluris, Inc. (the “Settlement
Administrator”) to send this Notice, calculate and make payments, and process Class Members’ Requests
for Exclusion. The Settlement Administrator will also decide Class Member Challenges over workweeks
or pay periods, mail and re- mail settlement checks and tax forms, and perform other tasks necessary to
administer the Settlement. The Settlement Administrator’s contact information is contained in Section 9
of this Notice.
9. Participating Class Members’ Release. After the Judgment is final and FNL has fully funded the Gross
Settlement Amount 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 you
opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be
part of any other lawsuit against the Released Parties for the Released Claims
The Participating Class Members will be bound by the following release:
The “Released Parties” are the following: (a) Defendant and any temporary or
staffing agencies (including but not limited to Adecco, Bluecrew, Personal HR,
Randstad, Next Level Staffing, IWC, Compliant Care Staffing, Driven Talent, and
Eastridge) which provided any Class Members or PAGA Members for Defendant;
(b) the respective former and present parents (including but not limited to Fashion
Nova LLC), subsidiaries, affiliated corporations and entities, clients, vendors and
independent contractors of the entities identified in subparagraph (a); (c) the
successors and predecessors of the entities identified in subparagraphs (a) and (b);
and (d) each of the respective current, former, and future officers, directors,
members, managers, insurers, accountants, attorneys, investment bankers, trusts,
trustees, licensors, licensees, employees, consultants, vendors, payroll companies,
independent contractors, clients, partners, shareholders, joint venturers, and third-
party agents of any entities identified in subparagraphs (a) through (c).
Plaintiffs and all Participating Class Members, on behalf of themselves, their heirs, executors, administrators,
attorneys, agents, assigns, and any entities or businesses in which any of them have a controlling ownership
interest, release and discharge the Released Parties from all state, federal, or local claims, rights, demands,
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liabilities, and causes of action alleged in the Amended Complaint, or that could have been asserted based on
any facts alleged in the Amended Complaint, including but not limited to violations of California Labor Code
sections 201, 202, 203, 204, 206, 210, 215, 216, 218, 218.5, 218.6, 221, 223, 225, 225.5, 226, 226.3, 226.6, 226.7,
233, 246, 246.5, 354, 408, 500, 510, 512, 515, 516, 553, 558, 558.1, 1174, 1174.5, 1175, 1182, 1182.11, 1182.12,
1185, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2802, 6720; California Business and Professions Code sections
17200, et seq.; California Civil Code sections 3287, 3289; California Code of Civil Procedure section 1021.5;
and applicable Industrial Welfare Commission Wage Orders, and claims for failure to pay minimum wages and
overtime wages, including any overtime wages owed on bonuses, incentive pay, or other such compensation;
failure to pay wages for all hours worked, including for off the clock work; failure to provide meal periods; failure
to pay meal period premium wages; failure to provide rest periods; failure to pay rest period premium wages;
failure to reimburse for necessary business expenditures; failure to pay all wages due; failure to furnish complete,
accurate, itemized wage statements; failure to pay all earned wages timely during employment and at termination;
failure to maintain accurate records; failure to provide sick leave; failure to pay sick leave, including sick leave
owed on bonuses, incentive pay, or other such compensation; failure to maintain temperature providing
reasonable comfort; failure to adopt standards that minimize excessive indoor heat; and failure to provide
suitable seating (the “Class Released Claims”). Except as set forth in this paragraph and the paragraph below,
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. PAGA Members’ Release. After the Court’s judgment is final and FNL has paid the Gross Settlement
and separately paid the employer-side payroll taxes, all PAGA Members will be barred from asserting
PAGA claims against the Released Parties, whether or not they exclude themselves from the Settlement.
This means that all Released Parties, including those who are Participating Class Members and those who
opt-out of the class part of the Settlement, cannot sue, continue to sue, or participate in any other PAGA
claim against the Released Parties for the released claims described below.
Plaintiffs and all PAGA Members, on behalf of themselves, their heirs, executors, administrators, attorneys,
agents, assigns, and any entities or businesses in which any of them have a controlling ownership interest, and
the State of California, release and forever discharge the Released Parties from all claims, demands, rights,
liabilities and causes of action for civil penalties under California Labor Code Private Attorneys General Act of
2004 (Labor Code section 2698 et seq.) alleged in the Amended Complaint, or that could have been asserted
based on any facts ever alleged in the Amended Complaint or any LWDA notices related to any of the Actions,
including but not limited to violations of California Labor Code sections 201, 202, 203, 204, 206, 210, 215, 216,
218, 218.5, 218.6, 221, 223, 225, 225.5, 226, 226.3, 226.6, 226.7, 233, 246, 246.5, 354, 408, 500, 510, 512, 515,
516, 553, 558, 558.1, 1174, 1174.5, 1175, 1182, 1182.11, 1182.12, 1185, 1194, 1194.2, 1197, 1197.1, 1198, 1199,
2802, 6720, and applicable Industrial Welfare Commission Wage Orders, and claims for failure to pay minimum
wages and overtime wages, including any overtime wages owed on bonuses, incentive pay, or other such
compensation; failure to pay wages for all hours worked, including for off the clock work; failure to provide meal
periods; failure to pay meal period premium wages; failure to provide rest periods; failure to pay rest period
premium wages; failure to reimburse for necessary business expenditures; failure to pay all wages due; failure
to furnish complete, accurate, itemized wage statements; failure to pay all earned wages timely during
employment and at termination; and failure to maintain accurate records; failure to provide sick leave; failure
to pay sick leave, including sick leave owed on bonuses, incentive pay, or other such compensation; failure to
maintain temperature providing reasonable comfort; failure to adopt standards that minimize excessive indoor
heat; and failure to provide suitable seating (the “PAGA Released Claims”). The PAGA Released Claims do not
include the claims related to suitable temperature that have been resolved through a settlement in the case of Hill
v. Fashion Nova et al., Los Angeles Superior Court Case No. 21STCV40012.
4. HOW WILL THE SETTLEMENT ADMINISTRATOR CALCULATE MY PAYMENT?
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1. Individual Class Payments. The Settlement 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 during the Class Period, and (b) multiplying the result by the number of workweeks worked by
each individual Participating Class Member.
2. Individual PAGA Payments. The Settlement Administrator will calculate Individual PAGA Payments by
(a) dividing $50,000 by the total number of pay periods worked by all PAGA Members during the PAGA
Period and (b) multiplying the result by the total number of such pay periods worked by each individual
PAGA Member.
3. Workweek/Pay Period Challenges. The number of workweeks you worked during the Class Period and
the number of pay periods you worked during the PAGA Period, as recorded in the records of FNL or the
staffing agencies are stated in the first page of this Notice. You have until October 26, 2026, to challenge
the number of workweeks and/or pay periods credited to you. You can submit your challenge by signing
and sending a letter to the Settlement Administrator via mail, email or fax. Section 9 of this Notice has
the Settlement Administrator’s contact information.
You need to support your challenge by sending copies of pay stubs or other records. The Settlement
Administrator will accept FNL’s and the staffing agencies’ calculation of workweeks and/or pay periods
based on their records as accurate unless you send copies of records containing contrary information. You
should send copies rather than originals because the documents will not be returned to you. The Settlement
Administrator will resolve workweek and/or pay period challenges based on your submission and on input
from Class Counsel (who will advocate on behalf of Participating Class Members and PAGA Members)
and FNL’s counsel. The Settlement Administrator’s decision is final. You can’t appeal or otherwise
challenge its final decision.
5. HOW WILL I GET PAID?
1. Participating Class Members. The Settlement 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 PAGA Members. The single check will combine the Individual Class Payment and the
Individual PAGA Payment.
2. Non-Participating Class Members. The Settlement Administrator will send, by U.S. mail, a single
Individual PAGA Payment check to every PAGA Member who opts out of the Class Settlement (i.e.,
every Non-Participating Class Member).
Your check will be sent to the same address as this Notice. If you change your address, be sure to
notify the Settlement Administrator as soon as possible. Section 9 of this Notice has the Settlement
Administrator’s contact information.
6. HOW DO I OPT-OUT OF THE CLASS SETTLEMENT?
Submit a written and signed postcard or letter that must: (1) contain the name, address, telephone number and the
last four digits of the Social Security number of the Class Member; (2) contain a statement that the Class Member
wishes to be excluded from the Settlement Class; (3) be signed by the Class Member. You must make the request
yourself. If someone else makes the request for you, it will not be valid. The Settlement Administrator must be
sent your request to be excluded by October 26, 2026, or it will be invalid. Section 9 of the Notice has the
Settlement Administrator’s contact information.
7. HOW DO I OBJECT TO THE SETTLEMENT?
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Only Participating Class Members have the right to object to the Settlement. Before deciding whether to object,
you may wish to see what Plaintiffs and FNL are asking the Court to approve. On September 25, 2026, Class
Counsel and 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 Class
Representative Enhancement Payments stating (i) the amount Class Counsel is requesting for attorneys’ fees and
litigation expenses; and (ii) the amount Plaintiffs are requesting as Class Representative Enhancement Payments.
Upon reasonable request, Class Counsel (whose contact information is in Section 9 of this Notice) will send you
copies of these documents at no cost to you. You can also view them on the Case Website
www.BuciovFNLogisticsClassAction.com or the Court’s website https://www.lacourt.ca.gov/pages/lp/access-a-
case/tp/find-case-information/cp/os-civil-case-access.
A Participating Class Member who disagrees with any aspect of the Settlement, the Motion for Final Approval
and/or Motion for Fees, Litigation Expenses and Enhancement Payments 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 Settlement Administrator is October 26, 2026. Be
sure to tell the Settlement Administrator what you object to, why you object, and any facts that support your
objection. Make sure you identify the Action and include your name, current address, telephone number, and
approximate dates of employment and sign the objection. Section 9 of this Notice has the Settlement
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 Section 8 of this Notice (immediately below)
for specifics regarding the Final Approval Hearing.
8. CAN I ATTEND THE FINAL APPROVAL HEARING?
You can, but don’t have to, attend the Final Approval Hearing on December 1, 2026, at 9:00 a.m. in Department
6 of the Los Angeles Superior Court, 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
Amount will be paid to Class Counsel, Plaintiffs, and the Settlement Administrator. The Court will invite
comment from objectors, Class Counsel and Defense Counsel before making a decision. You 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. You should check the Settlement
Administrator’s 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 Settlement Agreement sets forth everything FNL and Plaintiffs have promised to do under the proposed
Settlement. The easiest way to read the Settlement Agreement, the Judgment or any other Settlement documents
is to go to the case website at www.BuciovFNLogisticsClassAction.com. You can also telephone or send an
email to Class Counsel or the Settlement Administrator using the contact information listed below, or consult the
Superior Court website by going to http://www.lacourt.org/casesummary/ui/index.aspx) and entering the Case
Number for the Action, Case No. No. 22STCV26948. You can also make an appointment to personally review
court documents in the Clerk’s Office at the Stanley Mosk Courthouse by calling (213) 830-0800.
DO NOT TELEPHONE THE SUPERIOR COURT TO OBTAIN INFORMATION
ABOUT THE SETTLEMENT.
Class Counsel:
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Joseph Lavi, Esq.
Vincent C. Granberry, Esq.
LAVI & EBRAHIMIAN, LLP
8889 W. Olympic Blvd., Suite 200
Beverly Hills, California 90211
Emails: [email protected]
[email protected]
Michael Nourmand, Esq.
James A. De Sario, Esq.
THE NOURMAND LAW FIRM, APC
8822 West Olympic Boulevard
Beverly Hills, CA 90211
Emails: [email protected]
[email protected]
Marcus Bradley, Esq.
Kiley Grombacher, Esq.
Lirit King, Esq.
BRADLEY/GROMBACHER, LLP
31365 Oak Crest Drive, Suite 240
Westlake Village, CA 91361
Email: [email protected]
[email protected]
[email protected]
Emil Davtyan, Esq.
David Yeremian, Esq.
David Keledjian, Esq.
David Arakelyan. Esq.
D.LAW, INC.
450 N. Brand Blvd., Ste. 840
Glendale, CA 91203
Emails: [email protected]
[email protected]
[email protected]
[email protected]
Settlement Administrator:
Name of Company: Simpluris
Email Address: [email protected]
Mailing Address: P.O. Box 26170, Santa Ana, CA 92799
Telephone: 833-647-9068
10. WHAT IF I LOSE MY SETTLEMENT CHECK?
If you lose or misplace your settlement check before cashing it, the Settlement 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 for instructions on how to retrieve the funds
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11. WHAT IF I CHANGE MY ADDRESS?
To receive your check, you should immediately notify the Settlement Administrator if you move or otherwise
change your mailing address.
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