SUPERIOR COURT OF THE STATE OF WASHINGTON, IN AND FOR THE COUNTY OF KING
NOTICE OF CLASS ACTION SETTLEMENT
You may be eligible for an estimated payment of $1,519.58 from a class action settlement
relating to your application for employment with
Team Car Care, LLC (d/b/a Jiffy Lube) and/or its related entities.
A Washington State Superior Court authorized this Notice. You are not being sued. This is not a solicitation from an
attorney.
• Jeffrey Hill (“Plaintiff” or “Class Representative”), filed a lawsuit against Team Car Care, LLC and Team Car Care
West, LLC (collectively, “Defendants,” and collectively with Plaintiff, the “Parties”) on behalf of himself and a class
of similarly situated applicants for employment. The lawsuit, Hill v. Team Car Care, LLC, et al., Case No. 24-2-
16983-1 SEA (the “Lawsuit”) is currently pending in King County Superior Court before Judge Samuel Chung. Plaintiff
claimed in the lawsuit that Defendants’ job postings for open positions in Washington did not disclose the wage scale
or salary range being offered. Defendants dispute Plaintiff’s claims and contend they have 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
Defendants 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 Defendants of $1,181,250 (“Maximum Settlement Fund”). On April 28, 2026, the
Court issued an order preliminarily approving the settlement and authorizing the Settlement Administrator Simpluris
(“Settlement Administrator”) to issue this Notice and Claim Form.
• You are receiving this Notice because Defendants’ 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,
from January 1, 2023, through the date of preliminary approval completed and maintained an application for a job
opening in the State of Washington with one or more of Defendants through a job posted on Defendants’ website or an
authorized third-party recruiting platform, where the job posting did not include a wage scale or salary range.”
• 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.TCCSettlement.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 August 21, 2026.
You may submit your claim online by visiting www.TCCSettlement.com and using
SUBMIT A CLAIM FORM the following information:
Unique ID: «ClaimLoginID»
PIN: «ClaimLoginPIN»
You may also submit your Claim Form to the Settlement Administrator by mail or email.
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 Defendants about the same legal claims in this Lawsuit. The deadline to request
exclusion from the settlement is August 21, 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 21, 2026.
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You may ask the Court for permission for you or your attorney to speak about your
objection at the Final Approval Hearing. The Final Approval Hearing will be held before
ATTEND THE FINAL Judge Samuel Chung on October 9, 2026, at 8:30 A.M. If you wish to attend the hearing
APPROVAL HEARING remotely, you may do so by using the following link:
Zoom Link: https://kingcounty.zoom.us/j/89932169600
If you do nothing, you will remain in the Settlement Class, but you will forfeit the
opportunity to receive any compensation and give up any right to sue Defendants, and
DO NOTHING
certain parties related to Defendants, 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 Defendants. You have legal rights and
options that you must 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 Samuel Chung of King County Superior Court is overseeing this class action. The case is titled Hill v. Team Car
Care, LLC, et al., Case No. 24-2-16983-1 SEA.
Jeffrey Hill is the Plaintiff or Class Representative. The companies he sued, Team Car Care, LLC and Team Car Care West,
LLC, are the Defendants.
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 Defendants violated Washington law, RCW 49.58.110, when they allegedly did not disclose the wage
scale or salary range being offered on job postings for open positions.
Defendants deny Plaintiff’s allegations and deny that they are 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.TCCSettlement.com.
4. Why is there a settlement?
The Court has not decided whether Plaintiff or Defendants 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. 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 Defendants.
5. How do I know if I am in the Settlement Class?
Defendants’ records show you are part of the Settlement Class because you applied for a job opening in Washington with
the Defendants between January 1, 2023, and April 28, 2026 (the “Settlement Class Period”), where the job posting did not
disclose the wage scale or salary range for the position.
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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.TCCSettlement.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 $1,519.58.
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 August 21, 2026, to the Settlement Administrator:
Hill v. Team Car Care, LLC, et al.
P.O. Box 26170
Santa Ana, CA 92799
Email: [email protected]
Phone: 1-888-369-3780
You can also complete your claim form online at www.TCCSettlement.com using Unique ID: «ClaimLoginID» PIN:
«ClaimLoginPIN».
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 August 21, 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 October 9, 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 120 days
after the date of issuance.
9. Will Defendants retaliate against me if I participate in the settlement?
No. Defendants support 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 Defendants or Defendants’ 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
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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 Defendants agree not to oppose, an award of attorneys’ fees in the amount
of $348,468.75, plus costs and expenses in an amount not to exceed $5,000, to be paid from the Settlement Fund. Class
Counsel will also request a service award for Plaintiff in the amount of $15,000, 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, Defendants 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 release, waive, and forever discharge: (i) Defendants, and each of their 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 Defendants or any of their parents
and/or affiliates), investors, owners, joint ventures, joint employers, alter-egos, divisions, insurers,
insurance policies, and benefit plans, or any other entity with an interest in or obligation regarding
Defendants’ 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; (iii) any individuals or entities
that assisted Defendants or any of the other individuals and entities described in subsections (i) and (ii) of
this Paragraph 18, with creating, publishing, processing, or hosting any of the job postings used or
maintained by Defendants during the Settlement Class Period or otherwise assisted Defendants with its
employee recruitment efforts; and (iv) 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 asserted against the Released Parties by Plaintiff and members of the
Settlement Class in the Complaint (the “Released Class Claims”). The Released Class Claims include
claims based on the Released Parties’ alleged failure to comply with the job posting/pay transparency
requirements of the Washington Equal Pay and Opportunities Act, including, but not limited to, any alleged
liabilities arising out of or relating to a failure to include the wage scale or salary range and/or a general
description of all of the benefits and other compensation to be offered to a hired applicant or employee in
any job postings. The Released Class Claims also specifically include any 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 and/or RCW
49.58.110, interest, liquidated damages, exemplary damages, statutory damages, minimum statutory
damages, and attorneys’ fees and costs relating to any of the foregoing.
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By being part of the settlement, Settlement Class Members agree that they cannot sue or seek recovery against Defendants
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 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
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
Defendants 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 Defendants, 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 August 21, 2026, to the
Settlement Administrator at the following address:
Hill v. Team Car Care, LLC, et al.
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 Hill v.
Team Car Care, LLC, et al., Case No. 24-2-16983-1 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 Defendants for the same thing later?
No. Unless you exclude yourself, you give up any right to sue Defendants 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,
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you must file written notice with the Court stating that you object to the settlement in Hill v. Team Car Care, LLC, et al.,
Case No. 24-2-16983-1 SEA, no later than August 21, 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
516 Third Avenue, Room C-203
Seattle, WA 98104
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 Defendants’ attorneys at the addresses listed below, postmarked no later than August
21, 2026:
Class Counsel Defendants’ Counsel
Timothy W. Emery Peter H. Nohle
Patrick B. Reddy Jackson Lewis P.C.
Paul Cipriani 520 Pike Street, Suite 2300
Emery Reddy, PC Seattle, WA 98101
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 Samuel Chung on October 9, 2026, at 8:30 A.M. in King
County Superior Court, King Courthouse, 516 Third Avenue, Courtroom W-829, Seattle, WA 98104. If you wish to attend
the hearing remotely, you may do so by using the following link:
Zoom Link: https://kingcounty.zoom.us/j/89932169600
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.
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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.TCCSettlement.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.TCCSettlement.com.
You may contact the Settlement Administrator by phone, email, or in writing at:
Hill v. Team Car Care, LLC, et al.
P.O. Box 26170
Santa Ana, CA 92799
Email: [email protected]
Phone: 1-888-369-3780
PLEASE DO NOT CALL THE COURT, THE CLERK OF THE COURT, THE JUDGE, OR DEFENDANTS
WITH QUESTIONS ABOUT THE SETTLEMENT OR CLAIMS PROCESS.
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