SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
Andrea Velazquez v. Festival Fun Parks, LLC, Case No. 24STCV20667
TO ALL PERSONS RESIDING IN THE UNITED STATES WHO PURCHASED
ADMISSION TICKETS FROM WWW.RAGINGWATERS.COM BETWEEN JUNE 1,
2020, AND JUNE 22, 2026, AND PAID A “PROCESSING FEE.”
Para obtener información en español, visite www.RagingWatersSettlement.com.
A court authorized this Notice. This is not a solicitation from a lawyer.
• The Settlement resolves a lawsuit alleging that Defendant used drip pricing by failing to adequately
disclose a mandatory processing fee that was added near the end of the checkout process when
purchasing admission tickets from www.ragingwaters.com.
• The two sides disagree on whether Plaintiff and the Settlement Class could have prevailed at trial.
By entering into the Settlement, Defendant has not conceded the truth or validity of any of the
claims against it and denies any liability or wrongdoing.
• Defendant has agreed to pay Settlement Payments and other expenses, as described below, to fully
resolve and release certain claims of all persons residing in the United States who purchased
admission tickets from www.ragingwaters.com between June 1, 2020, and June 22, 2026, and paid
a “Processing Fee.”
• Under the Settlement, Settlement Class Members who submit a timely and valid claim are entitled
to a cash Settlement Payment.
• Settlement Class Members who wish to receive a Settlement Payment through the Settlement must
submit a Claim Form, as instructed below. Settlement Class Members who made more than one
purchase during the Class Period only need to submit one Claim Form to receive their Settlement
Payment.
• Your legal rights may be affected whether you act, or don’t act. Read this Notice carefully.
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Your Legal Rights and Options in This Settlement:
DO NOTHING If you do nothing, you will not receive a Settlement Payment, and
you will be legally bound by any judgment approving the Settlement.
Per the Settlement Agreement, by doing nothing, you release “all
claims and causes of action that were alleged in the operative
complaint, or which arise from the same facts alleged in the operative
complaint in the Action” against Defendant. The operative
Complaint is available at www.RagingWatersSettlement.com
SUBMIT A CLAIM FORM If you submit a valid Claim Form by November 24, 2026, you will
receive a cash Settlement Payment in the form of a check or an
DEADLINE: electronic payment. If you placed more than one order during the
November 24, 2026 Class Period, you need only submit one Claim Form to receive your
Settlement Payment. The amount of the Settlement Payment will
depend on the proportion of total processing fees paid by each
claimant, the number of eligible claimants, and other expenses
associated with the Settlement. Per the Settlement Agreement, by
submitting a Claim Form, you release “all claims and causes of action
that were alleged in the operative complaint, or which arise from the
same facts alleged in the operative complaint in the Action against
Defendant. The operative Complaint is available at
www.RagingWatersSettlement.com.
EXCLUDE YOURSELF FROM This is the only option that allows you to sue Defendant on your own
THE CASE regarding the legal claims in this case, but you will not receive
compensation under the Settlement. The deadline for excluding
DEADLINE: yourself is September 28, 2026.
SEPTEMBER 28, 2026
OBJECT TO THE Write to the Court about why you do not like the Settlement. A
SETTLEMENT Settlement Class Member who objects still remains in the Settlement
Class and will receive a Settlement Payment if they submit a valid
DEADLINE: and timely Claim Form. The deadline for objecting is September 28,
SEPTEMBER 28, 2026 2026.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
• The Court in charge of this case must still decide whether to approve the Settlement. Settlement
Payments will be issued if the Court approves the Settlement and after appeals are resolved, if
any.
BASIC INFORMATION
1. Why was this Notice issued?
This Notice was issued because a court has conditionally “certified” this case as a class action lawsuit for
settlement purposes only and your rights may be affected. If you purchased admission tickets from
www.ragingwaters.com between June 1, 2020, and June 22, 2026, while residing in the United States and
paid a processing fee, you may have legal rights and options in this case. This Notice explains all of these
issues. The Superior Court of the State of California for the County of Los Angeles is overseeing this class
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action. The case is known as Andrea Velazquez v. Festival Fun Parks, LLC, Case No. 24STCV20667 (the
“Action”). The person who sued is called the Plaintiff. The company they sued is called the Defendant.
2. Why is this a class action?
In a class action, one or more people, called “Class Representatives” (in this case Andrea Velazquez, the
named “Plaintiff”), sue on behalf of all people who have similar claims. Together, these people are called a
Class or Class Members. One court resolves the issues for all Class Members, except for those who exclude
themselves from the Class. Here, the Court has certified a class action for settlement purposes only (the
“Settlement Class”). More information about why this is a class action can be found in the Court’s
Preliminary Approval Order, which is available at www.RagingWatersSettlement.com.
3. Why is there a settlement?
The Court did not decide in favor of Plaintiff or Defendant. Plaintiff thinks she would have prevailed at
trial. Defendant thinks the Plaintiff would not have won anything from a trial. But there was no trial. Instead,
both sides agreed to this Settlement. That way, both sides avoid the risk and cost of a trial, and the Settlement
Class Members will receive compensation. The Class Representative and her attorneys think the Settlement
is best for all Settlement Class Members.
THE CLAIMS IN THE LAWSUIT
4. What is the lawsuit about?
The lawsuit claims that Defendant violated California’s Unfair Competition Law by drip pricing. Plaintiff
alleges that Defendant used drip pricing by failing to adequately disclose a mandatory processing fee that
was added near the end of the checkout process when purchasing admission tickets on Defendant’s website.
The lawsuit also asserts a quasi-contract/unjust enrichment claim based on the same conduct. Defendant
denies any liability or wrongdoing. More information can be found in the Class Action Complaint, available
at www.RagingWatersSettlement.com.
MEMBERS OF THE SETTLEMENT CLASS
5. How do I know if I am a part of the Settlement Class?
The Court has certified this case for settlement purposes only as a class action. The Settlement Class consists
of all persons residing in the United States who purchased admission tickets from www.ragingwaters.com
between June 1, 2020, and June 22, 2026, and paid a “Processing Fee.”
Excluded from the Settlement Class are all persons who validly opt out of the Settlement in a timely manner;
governmental entities; the Parties’ lawyers (and their respective law firms); Defendant and any of its parents,
affiliates, subsidiaries, independent service providers and all of their respective employees, officers and
directors; the presiding judge in the Action or judicial officer presiding over the matter, and all of their
immediate families and judicial staff; and any natural person or entity that entered into a release with
Defendant prior to the Court’s final approval of this Settlement arising from the same processing fee
allegations on the Defendant’s website, www.ragingwaters.com, underlying the claims in the operative
complaint in the Action.
THE SETTLEMENT BENEFITS
6. What does the Settlement provide?
Under the Settlement, Festival Fun Parks has agreed to pay $850,000 into a Settlement Fund to pay: (a)
cash Settlement Payments to Settlement Class Members who submit valid claims; (b) reimbursement of
litigation costs to Class Counsel (subject to Court approval and estimated to be $13,965.86); (c) settlement
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notice and administration expenses (subject to Court approval and estimated to be $67,000); (d) attorneys’
fees (subject to Court approval and estimated to be $283,333.33); and (e) a Class Representative service
award (subject to Court approval and estimated to be $2,500). Settlement Class Members may choose to
receive their Settlement Payment through an electronic payment or through a mailed check.
7. How much will my payment be?
The amount of the Settlement Payment will depend on the proportion of the total processing fees paid by
each Eligible Claimant, the number of Eligible Claimants, and other expenses associated with the
Settlement. After any Court-approved reimbursements of litigation costs, settlement notice and
administration expenses, attorneys’ fees, and Class Representative service awards, the remainder of the
Settlement Fund will be distributed to Settlement Class Members who submit a timely and valid claim
based on the proportion each Eligible Claimant paid of the total processing fees collected by Defendant
from Settlement Class Members during the Class Period.
8. What am I giving up to stay in the Settlement Class?
Unless you exclude yourself from the Settlement, you will be part of the Settlement Class, and you will be
bound by the release of claims in the Settlement. This means that, if the Settlement is approved, you cannot
sue, continue to sue, or be part of any other lawsuit against Defendant or a related released party asserting
a Released Claim. The Released Claims include “all claims and causes of action that were alleged in the
operative complaint, or which arise from the same facts alleged in the operative complaint.” The operative
Class Action Complaint is available at www.RagingWatersSettlement.com. It also means that all the
Court’s orders will apply to you and legally bind you. If you sign the Claim Form or do nothing, you will
agree to release Defendant from any and all claims under federal and state law that arise from or relate to
the allegations concerning Defendant’s processing fees at issue in this action.
THE LAWYERS REPRESENTING YOU
9. Do I have a lawyer in this case?
Yes. The Court has appointed Dovel & Luner, LLP as Class Counsel to represent you and the Settlement
Class in this case. The lawyers at Dovel & Luner LLP have experience handling similar cases. More
information about the lawyers and their law firm is available at https://www.dovel.com.
10. Should I get my own lawyer?
You do not need to hire your own lawyer because Class Counsel is representing you and all the other
members of the Settlement Class. If you want someone other than Class Counsel to speak for you, you may
hire your own lawyer at your own expense.
11. How will the lawyers be paid?
Class Counsel may file a request for attorneys’ fees they sustained in litigating this case. Class Counsel will
request no more than $283,333.33 attorneys’ fees. Class Counsel may also request reimbursement of
litigation expenses of $13,965.86. Class Counsel may also ask the Court to approve an Incentive Award of
up to $2,500 to the Class Representative for her service as the Class Representative. The Court may award
less than the amounts requested.
HOW TO RECEIVE YOUR SETTLEMENT PAYMENT
12. How can I get compensation under the Settlement?
To receive the Settlement Payment, you must submit a valid Claim Form. Settlement Class Members who
placed more than one order during the Class Period only need to submit one Claim Form to receive their
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Settlement Payment. Settlement Class Members who do not submit a valid Claim Form by November 24,
2026, will not receive a Settlement Payment. A Claim Form is available on the internet at
www.RagingWatersSettlement.com. Read the instructions carefully, fill out the form, sign it, and submit it
online no later than November 24, 2026. You may also print out a Claim Form and submit it by mail if
postmarked by no later than November 24, 2026. If you choose to mail your Claim Form, you must mail it
to the Settlement Administrator at the following address:
Velazquez v. Festival Fun Parks
Attn: Claim Forms
1650 Arch Street, Suite 2210
Philadelphia, PA 19103
To receive a Settlement Payment, each Settlement Class Member must attest under penalty of perjury that
they were a United States resident who purchased admission tickets from www.ragingwaters.com between
June 1, 2020, and June 22, 2026, and paid a processing fee. Settlement Class Members must also attest
under penalty of perjury that the information they supplied in the Claim Form is true and correct to the best
of the Settlement Class Member’s knowledge. Failure to timely submit a valid Claim Form with all
requested information will result in the Settlement Class Member not receiving a Settlement Payment.
13. When would I receive compensation?
The Court will hold a hearing on November 9, 2026, at 9:00 a.m., to decide whether to approve the
Settlement. If the Court approves the Settlement, after that, there may be appeals. It is always uncertain
whether these appeals can be resolved, and resolving them can take time, perhaps more than a year.
Settlement Payments will be distributed after the Settlement is finally approved and all appeals (if any) have
been resolved in favor of the Settlement. The progress of the Settlement will be updated through information
posted at www.RagingWatersSettlement.com. Please be patient.
EXCLUDING YOURSELF FROM THE SETTLEMENT
14. How do I get out of the Settlement?
If you do not want a Settlement Payment under this Settlement, and you want to keep the right to sue or
continue to sue Defendant regarding the alleged processing fees that are the subject of the Action, then you
must take steps to get out of the Settlement Class. This is called excluding yourself from, or opting out of,
the Settlement Class.
To exclude yourself from the Settlement, you must send a letter by mail to the Settlement Administrator
that (a) states your name, address, and phone number; (b) is personally signed by you, and not your attorney
or anyone acting on your behalf; and (c) includes a statement unambiguously requesting to be excluded
from the Settlement and identifying the case name and number, such as “I request to be excluded from the
class Settlement in Andrea Velazquez v. Festival Fun Parks, LLC, Case No. 24STCV20667.” No request
for exclusion will be valid unless all of the information described above is included.
You must mail your exclusion request postmarked no later than September 28, 2026, to the Settlement
Administrator at the following address:
Velazquez v. Festival Fun Parks
Attn: Exclusions
P.O. Box 58220
Philadelphia, PA 19102
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15. If I do not exclude myself, can I sue Defendant for the same thing later?
No. If you do not exclude yourself, you give up any right to sue (or continue to sue) Defendant for the
claims that this Settlement resolves.
16. If I exclude myself, can I get compensation under this Settlement?
No. If you ask to be excluded, you will not get any compensation under the Settlement, and you cannot
object to the Settlement.
OBJECTING TO THE SETTLEMENT
17. How do I tell the Court that I do not agree with the Settlement?
You can ask the Court to deny approval of the Settlement by filing an objection. You can’t ask the Court to
order a different Settlement; the Court can only approve or reject the Settlement. If the Court denies
approval, no Settlement Payments will be sent out and the lawsuit will continue. If that is what you want to
happen, you must object. A Settlement Class Member who objects still remains in the Settlement Class and
must timely submit a Claim Form in order to obtain a Settlement Payment.
Any objection to the proposed Settlement must be in writing. If you file a timely written objection, you
may, but are not required to, appear at the Final Approval Hearing, either in person or through your own
attorney. If you appear through your own attorney, you are responsible for hiring and paying that attorney.
All written objections and supporting papers must (a) clearly identify the case name and number (“Andrea
Velazquez v. Festival Fun Parks, LLC, Case No. 24STCV20667”), and (b) be mailed to the Settlement
Administrator postmarked on or before September 28, 2026.
Velazquez v. Festival Fun Parks
Attn: Objections
P.O. Box 58220
Philadelphia, PA 19102
Written objections must also contain: (1) your full name, address, and telephone number; (2) a written
statement of all grounds for the objection accompanied by any legal support for the objection (if any); (3)
copies of any papers, briefs or other documents upon which the objection is based (if any); (4) a list of all
persons who will be called to testify in support of the objection (if any); (5) a statement of whether you or
your counsel intend to appear at the Final Approval Hearing; (6) proof of membership in the Settlement
Class or a signed statement attesting under penalty of perjury that you paid a processing fee when purchasing
admission tickets from the Raging Waters Website during the Class Period; and (7) your signature and your
attorney’s signature (if any).
18. What is the difference between objecting and excluding myself from the Settlement?
Objecting means telling the Court that you do not like something about the Settlement. You can object only
if you stay in the Settlement Class. Excluding yourself from the Settlement means that you do not want to
be part of the Settlement Class. If you exclude yourself, then you have no basis to object to the Settlement.
A Settlement Class Member who objects still remains in the Settlement Class and is eligible to receive a
Settlement Payment.
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IF YOU DO NOTHING
19. What happens if I do nothing at all?
If you do nothing, and the Court finally approves the settlement, you will remain a member of the Settlement
Class and you will give up your right to sue Defendant. You will not receive a Settlement Payment.
THE COURT’S FINAL APPROVAL HEARING
20. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Final Approval Hearing at 9:00 a.m. on November 9, 2026, in Department 6 at the
Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012. At this hearing, the Court will
consider whether the Settlement is fair, reasonable and adequate. If there are valid objections that comply
with the requirements herein, the Court also will consider them and will listen to people who have asked to
speak at the hearing. The Court may also decide how much to pay to Class Counsel and the Class
Representative.
The date of the Final Approval Hearing may change without further notice to the Settlement Class.
Settlement Class Members should check the Settlement Website to confirm that the date has not been
changed and whether the hearing may proceed virtually.
21. Do I have to come to the hearing?
No. Class Counsel will appear on behalf of the Settlement Class. But you are welcome to come, or have
your own lawyer appear, at your own expense.
22. May I speak at the hearing?
You, or any lawyer you retain, may speak at the Final Approval Hearing, if you or the lawyer you retain
appears at the hearing and requests an opportunity to speak.
TAX CONSEQUENCES
23. Do I have to pay taxes on money received under this Settlement?
None of Defendant, Class Counsel, or the Settlement Administrator is able provide any advice or
guidance regarding the tax consequences of the Settlement as to any Settlement Class Member. Settlement
Class Members should consult their own tax advisors regarding the tax consequences of the Settlement
and any tax reporting obligations with respect thereto. Each Settlement Class Member is responsible for
his/her taxes or tax reporting and other obligations respecting the Settlement, if any.
GETTING MORE INFORMATION
24. Is this the entire Settlement?
No. This Notice is only a summary of the proposed Settlement. More information about the lawsuit and the
precise terms and conditions of the Settlement is available at www.RagingWatersSettlement.com, or by
calling toll-free (888) 558-4218, or by writing to the Settlement Administrator at Velazquez v. Festival Fun
Parks, 1650 Arch Street, Suite 2210, Philadelphia, PA 19103, or by visiting the Court to review the case’s
docket at Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012, between 8:30 a.m. and
4:30 p.m., Monday through Friday, excluding court holidays. The Los Angeles Superior Court recommends
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making an appointment online before visiting a courthouse for copies of documents. You may also contact
Class Counsel using the information listed below:
Dovel & Luner, LLP
Simon Franzini
Martin Brenner
Grace Bennett
DOVEL & LUNER, LLP
201 Santa Monica Blvd., Suite 600
Santa Monica, California 90401
[email protected]
Please do not telephone the Court or the Court Clerk’s Office to inquire about
this Settlement or the Claims Process.
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