Karen Roberts et al. v. Long Beach Community College District (Case No. 22STCV11381) COURT APPROVED NOTICE OF CLASS ACTION SETTLEMENT AND HEARING DATE FOR FINAL COURT APPROVAL 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 the settlement of a class action lawsuit (“Action”) against Long Beach Community College District (“District”) for alleged minimum wage violations. The Action was filed by District part-time faculty members Karen Roberts and Seija Rohkea (“Plaintiffs”) and seeks payment of back wages, liquidated damages, and interest for a class of part-time hourly instructional faculty members (“Class Members”) who worked for District during the Class Period (April 5, 2019 through August 25, 2025). Based on District’s records, and the Parties’ current assumptions, your Individual Class Payment is estimated to be $_______ (less withholding). The actual amount you may receive may be different and will depend on a number of factors. The above estimates are based on the District’s records showing that you were assigned to teach ________ Weekly Credit Hours during particular terms during the Class Period. If you believe that you were assigned to teach more Weekly Credit Hours during this 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 District to make payments under the Settlement and requires Class Members to give up their rights to assert certain claims against District. If you worked for District during the Class Period, you have two basic options under the Settlement: (1) Do Nothing and Receive a Settlement Payment. You don’t have to do anything to participate in the proposed Settlement and be eligible for an Individual Class Payment. However, as a Participating Class Member, you will give up your right to assert Class Period wage claims against District. (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 Administrator in writing. If you opt-out of the Settlement, you will not receive an Individual Class Payment. However, you will preserve your right to personally pursue Class Period wage claims against District. The District will not retaliate against you for any actions you take with respect to the Page 1 of 8 RobertsLBCCDClassAction.com (833) 360-6746 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, Anything If You Want eligible for an Individual Class Payment. In exchange, you will to Participate in the give up your right to assert the wage claims against District that are Settlement covered by this Settlement (Released Claims). You Can Opt-out of If you don’t want to fully participate in the proposed Settlement, the Class Settlement you can opt-out of the Class Settlement by sending the Administrator a written Request for Exclusion. Once you opt out, The Opt-out Deadline you will be a Non-Participating Class Member and you will no is December 3, 2026 longer be eligible for an Individual Class Payment. Non- Participating Class Members cannot object to any portion of the proposed Settlement. See Section 6 of this Notice. Participating Class All Class Members who do not opt-out of the Settlement Members Can Object (“Participating Class Members”) can object to any aspect of the to the Class Settlement proposed Settlement. The Court’s decision whether to finally approve the Settlement will include a determination of how much Written Objections will be paid to Class Counsel and Plaintiffs who pursued the Must be Submitted by Action on behalf of the Class. You are not personally responsible December 3, 2026 for any payments to Class Counsel or Plaintiffs, but every dollar paid to Class Counsel and Plaintiffs reduces the overall amount paid to Participating Class 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 Court’s Final Approval Hearing is scheduled to take place on the February 9, 2027 February 9, 2027. You don’t have to attend but you do have the Final Approval right to appear (or hire an attorney to appear on your behalf at your Hearing own cost), in person, by telephone or by using the Court’s virtual appearance platform. Participating Class Members can orally object to the Settlement at the Final Approval Hearing. See Section 8 of this Notice. You Can Challenge the The amount of your Individual Class Payment depends on the Calculation of Your number and dates of Weekly Credit Hours that you were assigned Weekly Credit Hours to teach during the Class Period. The number of Weekly Credit Hours you were assigned to teach during the Class Period, Written Challenges according to District’s records, is stated on the first page of this Must be Submitted by Notice. If you disagree with this number, you must challenge it by December 3, 2026 December 3, 2026. See Section 4 of this Notice. 1. WHAT IS THE ACTION ABOUT? This lawsuit is about whether District violated California’s minimum wage laws by failing to pay part-time instructional faculty members at least the minimum wage for all hours worked. Specifically, Plaintiffs contend Page 2 of 8 RobertsLBCCDClassAction.com (833) 360-6746 that the District unlawfully fails to compensate part-time instructional faculty for any time worked outside of classroom teaching hours. District denies it has violated the minimum wage, or other laws, related to its compensation of part-time instructional faculty members, which compensation was negotiated through a collective bargaining agreement with the plaintiffs’ union, the Certificated Hourly Instructors (CHI). Plaintiffs are represented by attorneys in the Action: Altshuler Berzon LLP and Tuttle & McCloskey, PC (“Class Counsel”). The District has denied violating any laws or failing to pay any wages and contended it complied with all applicable laws. The Court has found that the District’s compensation for part-time instruction faculty members does not comply with minimum wage law, but has not determined how much money is owed to the Class. 2. WHAT DOES IT MEAN THAT THE ACTION HAS SETTLED? Instead of conducting a trial to determine the amount of money owed to the Class, and to eliminate the risk of further litigation, including appeals, Plaintiffs and the District have decided to settle this case. Plaintiffs and District hired an experienced neutral mediator to help them resolve the Action by negotiating to end the case by agreement (settle the case) rather than continuing the expensive and time- consuming process of litigation. The negotiations were successful. By signing a lengthy written settlement agreement (“Agreement”) and agreeing to jointly ask the Court to enter a judgment ending the Action and enforcing the Agreement, Plaintiffs and District have negotiated a proposed Settlement 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, District 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) District 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. 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. District Will Pay $18 Million ($18,000,000) as the Gross Settlement Amount (Gross Settlement). District has agreed to deposit the Gross Settlement into an account controlled by a neutral third- party Settlement Administrator. The Administrator will use the Gross Settlement to pay the Individual Class Payments, Class Representative Service Payments, Class Counsel’s attorneys’ fees and expenses, and the Administrator’s expenses. Assuming the Court grants Final Approval, District will fund the Gross Settlement not more than 14 days after the Judgment entered by the Court become final. The Judgment will be final on the date the Court enters Judgment, or a later date if Participating Class Members object to the proposed Settlement or the Judgment is appealed. 2. Court Approved Deductions from Gross Settlement. At the Final Approval Hearing, Plaintiff and/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement, the amounts of which will be decided by the Court at the Final Approval Hearing: A. Up to $1,440,000 (8% of the Gross Settlement) to Class Counsel for attorneys’ fees and up to $50,000 for their litigation expenses. Page 3 of 8 RobertsLBCCDClassAction.com (833) 360-6746 B. Up to $20,000 to each of the Plaintiffs (for a total of $40,000) as Class Representative Awards for filing the Action, working with Class Counsel and representing the Class. A Class Representative Award will be the only monies each Plaintiff will receive other than that Plaintiff’s Individual Class Payment. C. Up to $16,000 to the Administrator for services administering the Settlement. 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 Administrator will distribute the rest of the Gross Settlement (the “Net Settlement”) by making Individual Class Payments to Participating Class Members based on their Class Period Weekly Credit Hours. You do not have to make a claim or fill out a form to receive an Individual Class Payment. 4. Taxes Owed on Payments to Class Members. Plaintiffs and District are asking the Court to approve an allocation of 50% of each Individual Class Payment to taxable wages (“Wage Portion”) and 50% to liquidated damages and interest (“Non-Wage Portion”). The Wage Portion is subject to withholdings and will be reported on IRS W-2 Forms. The District will separately pay employer payroll taxes it owes on the Wage Portion. The Administrator will report the Non-Wage Portions of the Individual Class Payments on IRS 1099 Forms. Although Plaintiffs and District 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, if any) 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. Settlement Payment Checks Must be Cashed Promptly. The front of every check issued for Individual Class Payments will show the date when the check expires (the void date). If you don’t cash your check by the void date, it will be automatically cancelled, and the monies will be deposited with the California Controller’s Unclaimed Property Fund in your name. If the money represented by your check is sent to the Controller’s Unclaimed Property Fund, you should consult the Fund’s website at https://www.sco.ca.gov/search_upd.html for instructions on how to retrieve your money. 5. 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 Administrator in writing, not later than December 3, 2026, that you wish to opt-out. The easiest way to notify the Administrator is to send a written and signed Request for Exclusion by the December 3, 2026 Response Deadline. The Request for Exclusion should be a letter from a Class Member or his/her/their representative setting forth a Class Member’s name, present address, telephone number, and a simple statement electing to be excluded from the Settlement. If you opt out, you will not receive an Individual Class Payment, but you will preserve your rights to personally pursue wage and hour claims against District. See Section 6 of this Notice for more information. 6. 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 to enter a Judgment. It is also possible the Court will enter a Judgment that is reversed on appeal. Plaintiffs and District Page 4 of 8 RobertsLBCCDClassAction.com (833) 360-6746 have agreed that, in either case, the Settlement will be void. That means that District will not pay any money and Class Members will not release any claims against District. 7. Administrator. The Court has appointed a neutral company, Simpluris, Inc. (the “Administrator”), to send this Notice, calculate and make payments, and process Class Members’ Requests for Exclusion. The Administrator will also decide Class Member Challenges over Weekly Credit Hours, mail and re-mail settlement checks and tax forms, and perform other tasks necessary to administer the Settlement. The Administrator’s contact information is contained in Section 9 of this Notice. 8. Participating Class Members’ Release. After the Judgment is final and District has fully funded the Gross Settlement 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 opt out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against District or related entities for wages based on the Class Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: “All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint, including claims for unpaid minimum wages, liquidated damages and penalties thereon, and unpaid benefits contributions thereon. Participating Class Members do not release any other claims, including claims for 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.” 4. HOW WILL THE ADMINISTRATOR CALCULATE MY PAYMENT? 1. Individual Class Payments. The District has provided data included the Weekly Credit Hours that each Class Member was assigned to teach in each term. Weekly Credit Hours are weighted by the term in which they were taught to account for increases in the California minimum wage rate over the Class Period. The Administrator will calculate Individual Class Payments by (a) dividing the Net Settlement Amount by the total value of all Weekly Credit Hours worked by all Participating Class Members, and (b) multiplying the result by the value of the weighted Weekly Credit Hours worked by each individual Participating Class Member. 2. Weekly Credit Hour Challenges. The number of Weekly Credit Hours you worked during the Class Period, as recorded in District’s records, is stated in the first page of this Notice. You have until December 3, 2026 to challenge the number of Weekly Credit Hours. You can submit your challenge by signing and sending a letter to the Administrator via mail, email or fax. Section 9 of this Notice has the Administrator’s contact information. You must support your challenge by sending copies of pay stubs or other records. The Administrator will accept District’s calculation of Weekly Credit Hours based on District’s 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 Page 5 of 8 RobertsLBCCDClassAction.com (833) 360-6746 Administrator will resolve Weekly Credit Hour challenges based on your submission and on input from Class Counsel (who will advocate on behalf of Participating Class Members) and District’s Counsel. The Administrator’s decision is final. You can’t appeal or otherwise challenge the Administrator’s final decision. 5. HOW WILL I GET PAID? The 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). Your check will be mailed to the same address as this Notice. If you change your address, be sure to notify the Administrator as soon as possible. Section 9 of this Notice has the Administrator’s contact information. 6. HOW DO I OPT-OUT OF THE CLASS SETTLEMENT? Submit a written and signed letter with your name, present address, telephone number, and a simple statement that you do not want to participate in the Settlement. The Administrator will exclude you based on any writing communicating your request be excluded. Be sure to personally sign your request, identify the Action as Roberts v. Long Beach Community College District, and include your identifying information (full name, address, telephone number, approximate dates of employment, and social security number for verification purposes). You must make the request yourself. If someone else makes the request for you, it will not be valid. Your request must be postmarked or delivered by December 3, 2026, or it will be invalid. Section 9 of the Notice has the Administrator’s contact information. 7. HOW DO I OBJECT TO THE SETTLEMENT? 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 District are asking the Court to approve. At least 16 court days before the February 9, 2027 Final Approval Hearing, Class Counsel 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 Service Awards stating (i) the amount Class Counsel is requesting for attorneys’ fees and litigation expenses; and (ii) the amount Plaintiffs are requesting as a Class Representative Service Award. 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 case documents on the Administrator’s Website: www.RobertsLBCCDClassAction.com or the Court’s website: https://www.lacourt.ca.gov/pages/lp/access-a-case/tp/find-case-information. A Participating Class Member who disagrees with any aspect of the Agreement, the Motion for Final Approval and/or Motion for Fees, Litigation Expenses and Service Award 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 Administrator is December 3, 2026. Be sure to tell the Administrator what you object to, why you object, and any facts that support your objection. Make sure you identify the Action, Roberts v. Long Beach Community College District, and include your name, current address, telephone number and approximate dates of employment with the District and sign the objection. Section 9 of this Notice has the 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 Page 6 of 8 RobertsLBCCDClassAction.com (833) 360-6746 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 February 9, 2027 at 10 a.m. in Department 11 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 will be paid to Class Counsel, the Class Representatives, and the Administrator. The Court will invite comment from objectors, Class Counsel and the District’s 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. The Court may reschedule the Final Approval Hearing. You should check the Administrator’s website www.RobertsLBCCDClassAction.com beforehand or contact Class Counsel to verify the date and time of the Final Approval Hearing. 9. HOW CAN I GET MORE INFORMATION? The Agreement sets forth everything District and Plaintiffs have promised to do under the proposed Settlement. The easiest way to read the Agreement, the Judgment or any other Settlement documents is to visit the Administrator’s website at www.RobertsLBCCDClassAction.com. You can also telephone or send an email to Class Counsel or the 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. 22STCV11381. 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: Eileen B. Goldsmith Joshua F. Richtel Altshuler Berzon LLP Tuttle & McCloskey, PC 177 Post St., Suite 300 750 E. Bullard Ave., Suite 101 San Francisco, CA 94108 Fresno, CA 93710 Email: egoldsmith@altber.com Email: joshr@t-m-law.com Settlement Administrator: Name of Company: Simpluris Email Address: Info@ RobertsLBCCDClassAction.com Mailing Address: P.O. Box 26170, Santa Ana, CA 92799 Telephone: (833) 360-6746 Fax Number: 714-917-7455 10. WHAT IF I LOSE MY SETTLEMENT CHECK? If you lose or misplace your settlement check before cashing it, the 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 at Page 7 of 8 RobertsLBCCDClassAction.com (833) 360-6746 https://www.sco.ca.gov/search_upd.html for instructions on how to retrieve the funds. 11. WHAT IF I CHANGE MY ADDRESS? To make sure you receive your check, or any other important information regarding this case, you should immediately notify the Administrator if you move or otherwise change your mailing address. Page 8 of 8 RobertsLBCCDClassAction.com (833) 360-6746