IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
NOTICE OF CLASS ACTION SETTLEMENT
You are eligible to receive an estimated payment of from a class action settlement relating to your application for
employment with Hydromax USA, LLC (“Hydromax”). The Honorable Matthew Lapin of King County Superior
Court authorized this notice. This is not a solicitation from an attorney. Please read carefully.
• Jeffrey Hill (“Plaintiff” or “Class Representative”), filed a lawsuit against Hydromax USA, LLC (“Defendant,” and
collectively with Plaintiff, the “Parties”) on behalf of himself and a class of similarly situated applicants for employment.
The lawsuit, Jeffrey Hill v. Hydromax USA, LLC, Case No. 25-2-21725-6 SEA, (the “Lawsuit”) is currently pending in
King County Superior Court before Judge Matthew Lapin. Plaintiff claimed in the lawsuit that Defendant’s job postings
for open positions in Washington did not disclose the wage scale or salary range being offered. Defendant disputes
Plaintiff’s claims and contends it has not violated any law and Plaintiff’s claims are without merit.
• The Court has not made any determinations regarding the merits of the Plaintiff’s claims, and it has not decided whether
Defendant violated the law.
• The Parties to the Lawsuit have reached a proposed Class Action Settlement. The Proposed Class Action Settlement
includes a maximum payment by Defendant of $382,500.00 (“Maximum Settlement Fund”), depending on how many
Class Members submit a claim. On July 16, 2026, the Court issued an order preliminarily approving the settlement and
authorizing the Settlement Administrator Simpluris, Inc. (“Settlement Administrator”) to issue this Notice and Claim
Form.
• You are receiving this Notice because Defendant’s records indicate you are eligible to participate in the Class Action
Settlement as a member of the Settlement Class. “Settlement Class Members” include “Plaintiff and all individuals who
applied for a job opening in Washington with Hydromax USA, LLC where the job posting did not disclose the wage
scale or salary range and a general description of all of the benefits and other compensation to be offered to the hired
applicant from January 1, 2023, through July 16, 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.
• Please read this Notice carefully. Your legal rights are affected regardless of whether you act or do not act. For complete
details, please see the Settlement Agreement, the terms of which control, available at
www.EPOASettlementHUL.com.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
This is the only way you are eligible to receive a payment from this settlement. The
deadline to submit a Claim Form is October 12, 2026.
You may submit your claim online by visiting
SUBMIT A CLAIM FORM
www.EPOASettlementHUL.com.
You may also submit your Claim Form to the Settlement Administrator by mail or
email.
If you wish to be excluded, you must submit your opt-out request in accordance
with the instructions below. You will no longer be in the Settlement Class and will
EXCLUDE YOURSELF
not receive a settlement payment. This is the only option that allows you to keep
FROM THE SETTLEMENT
any right to sue Defendant about the same legal claims in this Lawsuit. The
deadline to request exclusion from the settlement is October 12, 2026.
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Notice of Class Action Settlement
Write to the Court explaining why you do not agree with the settlement. You must
OBJECT TO THE
not exclude yourself from the settlement if you wish to object. The deadline to
SETTLEMENT
object is October 12, 2026.
You may ask the Court for permission for you or your attorney to speak about your
ATTEND THE FINAL objection at the Final Approval Hearing. The Final Approval Hearing will be held
APPROVAL HEARING before Judge Matthew Lapin on December 18, 2026, at 8:30 A.M. For hearing
location information, please see below in section 20.
If you do nothing, you will remain in the Settlement Class but will forfeit the
opportunity to receive any compensation and give up any right to sue Defendant,
DO NOTHING
and certain parties related to Defendant, about the claims that have been or could
have been asserted based on the facts alleged in this Lawsuit.
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 with Defendant. You have legal rights and
options that you may act on before the Court decides whether to approve the proposed settlement. You may be eligible to
receive a cash payment as part of the settlement. This Notice explains the Lawsuit, the Class Action Settlement Agreement
(“Settlement Agreement”), and your legal rights.
Judge Matthew Lapin of King County Superior Court is overseeing this class action. The case is titled Jeffrey Hill v.
Hydromax USA, LLC, Case No. 25-2-21725-6 SEA
Jeffrey Hill is the Plaintiff or Class Representative. The company he sued, Hydromax USA, LLC, is the Defendant.
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 49.58.110, when it allegedly did not disclose the wage scale
or salary range being offered on job postings for open positions.
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 “Documents” section of the Settlement Website at www.EPOASettlementHUL.com.
4. Why is there a settlement?
The Court has not decided whether the Plaintiff or Defendant should win this case. Instead, both sides agreed to this
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. The 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.
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Notice of Class Action Settlement
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 applied for a job opening in Washington with
the Defendant between January 1, 2023, and July 16, 2026 (the “Settlement Class Period”), where the job posting did not
disclose the wage scale or salary range for the position.
If you are still not sure whether you are included, you can contact the Settlement Administrator by calling toll-free at 1-888-
369-3780, emailing [email protected] or by visiting the Settlement Website at
www.EPOASettlementHUL.com.
THE SETTLEMENT BENEFITS
6. What does the settlement provide?
All Settlement Class Members who submit a timely, valid Claim Form are eligible to receive an equal share of the Net
Settlement Fund. Your estimated payment amount is on the Claim Form you received with this Notice.
Settlement payments will be characterized as non-wage damages (1099).
7. How do I receive a payment?
To qualify for a settlement payment, you must complete the enclosed Claim Form and submit it by email or mail,
postmarked on or before October 12, 2026, to the Settlement Administrator:
Jeffrey Hill v. Hydromax USA, LLC
c/o Simpluris, Inc.
P.O Box 26170
Santa Ana, CA 92799
[email protected]
(888) 369-3780
You can also complete your claim form online at www.EPOASettlementHUL.com.
Claims will be subject to a verification process, and the Settlement Administrator may request additional information. All
Claim Forms must be submitted or postmarked on or before October 12, 2026.
To ensure you receive your payment, you must contact the Settlement Administrator if your address or phone
number changes at any time.
8. When will I get my payment?
The hearing to consider the fairness of the settlement is scheduled for December 18, 2026, at 8:30 A.M. If the Court
approves the settlement, eligible Settlement Class Members who submitted a timely, valid Claim Form will be mailed a
check after all appeals and other reviews, if any, are completed. Please be patient. All checks 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 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 any
application for employment with Defendant or Defendant’s treatment of you as a current or former employee.
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Notice of Class Action Settlement
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 $112,838.00, plus costs and expenses in an amount not to exceed $5,000.00, to be paid from the Maximum Settlement
Fund. Class Counsel will also request a service award for Plaintiff in the amount of $15,000.00, to be paid from the
Maximum 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 and Released Parties will be
“released” from claims as described in Paragraph 18 of the Settlement Agreement, which states that upon final approval of
this Settlement Agreement by the Court, each Settlement Class Member who does not submit a valid and timely request for
exclusion:
“…will be deemed for all purposes to have released, waived, and forever discharged Defendant of and
from any and all claims that arose during the Settlement Class Period that were asserted against the
Released Parties by Plaintiff [and] Settlement Class Members in the Action (the “Released Class
Claims”). Specifically, the Released Class Claims are claims arising out of or relating to a violation of
RCW 49.58.110, and any attendant claims for relief under RCW 49.58.070, such as interest, liquidated
damages, exemplary damages, statutory damages, and attorneys’ fees and costs.”
By being part of the settlement, Settlement Class Members agree that they cannot sue or seek recovery against Defendant
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 the applicable deadline 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, you will receive no payment under the settlement. You will still be in the Settlement Class, and, if the
Court approves the settlement, you will be bound by all orders and judgments of the Court, the Settlement Agreement, and
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Notice of Class Action Settlement
its included release. You will be deemed to have participated in the settlement and will be subject to the provisions of
Section 12 above. 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 receive no benefits or payment under the
settlement. However, you will not be in the Settlement Class, will not release claims against Defendant, and 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 October 12, 2026, to the
Settlement Administrator at the following address:
Jeffrey Hill v. Hydromax USA, LLC
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 (for example, “I request to be excluded from the class action settlement in Jeffrey
Hill v. Hydromax USA, LLC, Case No. 25-2-21725-6 SEA.”); 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, do not submit a Claim Form to ask for a payment.
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 Jeffrey Hill v. Hydromax USA, LLC,
Case No. 25-2-21725-6 SEA, no later than October 12, 2026. Your objection must be filed with the Court, which you can
do by mailing your objection and any supporting documents to King County Superior Court at the following address:
King County Superior Court
401 Fourth Avenue North, Room 2D
Kent, WA 98032
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)
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Notice of Class Action Settlement
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 October
12, 2026:
Class Counsel Defendant’s Counsel
Timothy W. Emery Paul J. Bruene
Patrick B. Reddy Baker & Hostetler LLP
Paul Cipriani 999 Third Avenue, Suite 3900
Emery Reddy, PC Seattle, WA 98104
600 Stewart Street, Suite 1100
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 Matthew Lapin on December 18, 2026, at 8:30 A.M. in King
County Superior Court, Maleng Regional Justice Center, 401 Fourth Avenue North, Courtroom 4G, Kent, WA 98032.
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
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.EPOASettlementHUL.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.
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Notice of Class Action 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.EPOASettlementHUL.com.
You may contact the Settlement Administrator by phone, email, or in writing at:
Jeffrey Hill v. Hydromax USA, LLC
c/o Simpluris, Inc.
P.O Box 26170
Santa Ana, CA 92799
[email protected]
(888) 369-3780
PLEASE DO NOT CALL THE COURT, THE CLERK OF THE COURT, THE JUDGE, OR DEFENDANT
WITH QUESTIONS ABOUT THE SETTLEMENT OR CLAIMS PROCESS.
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Notice of Class Action Settlement
