Question 1

What is This Case About?

Accepted Answer

Plaintiffs filed this lawsuit on behalf of non-exempt hourly employees who
worked for Defendants at their manufacturing facilities. Plaintiffs allege that
Defendants failed to pay employees for all compensable time worked, including
certain pre- and post-shift work, and that Defendants’ timekeeping practices
resulted in employees not being paid for all time actually worked. Plaintiffs
seek unpaid wages, statutory damages, interest, attorneys’ fees, and costs.
Defendants deny all liability and contend they complied with the law.

Question 2

What is a Class Action and a Collective Action?

Accepted Answer

This lawsuit includes both:

* A Federal Rule of Civil Procedure 23 class action for certain Virginia
   state-law wage and related claims. If the Court approves the settlement, most
   people covered by the Virginia classes will be included automatically unless
   they opt out.
 * An FLSA nationwide collective action for federal wage claims under the Fair
   Labor Standards Act (“FLSA”). Only individuals who filed an FLSA Consent Form
   in this case are part of the FLSA collective for settlement purposes. If you
   did not file a Consent Form, you are not part of the FLSA settlement group.

Question 3

Am I Included in the Settlement?

Accepted Answer

Defendants’ records show you may be in one or more of the following groups:

1. Virginia Wage Class – You are a member of the Virginia Wage Class if you
    worked for one or more Defendants in Virginia as a non-exempt hourly
    employee at any time from April 12, 2018 through February 10, 2026, and your
    employment falls within the class definition approved by the Court and set
    forth in the Settlement Agreement.
 2. Breach of Contract Class – You are a member of the Breach of Contract /
    Quantum Meruit Class if you worked for one or more Defendants in Virginia as
    a non-exempt hourly employee at any time from April 12, 2016 through
    February 10, 2026, and your employment falls within the class definition
    approved by the Court and set forth in the Settlement Agreement.
 3. FLSA Class – You are a member of the FLSA Class only if you previously filed
    a written Consent to Join this lawsuit under the FLSA.

If you are unsure whether you are included, you may contact the Settlement
Administrator by calling toll-free at 1-800-384-4310 or visiting the Contact
[contact] page.

Question 4

What Are the Terms of the Settlement?

Accepted Answer

* Defendants will pay a total of $3,000,000.00 (the “Settlement Amount”), plus
   any employer payroll taxes/withholdings ordinarily borne by employers on the
   payroll portion.
    
 * The Settlement Amount will be reduced by Court-approved:
   * Settlement administration costs (up to $35,000.00),
   * Litigation costs/expenses ($209,155.51),
   * Attorneys’ fees (requested at $1,000,000.00, which is one-third of the
     Settlement Amount), and
   * Service awards (requested total $50,000.00 – $25,000 each for the two Named
     Plaintiffs).
      
 * After these deductions, the amount available for payments to class/collective
   members is the Net Settlement Amount: $1,705,844.49.
    
 * The Net Settlement Amount will be allocated as follows:
   * $1,446,842.20 – Virginia Wage Class Fund (for Virginia wage claims)
   * $200,986.25 – Breach of Contract Class Fund (for contract/quantum
     meruit/unjust enrichment claims)
   * $58,016.04 – FLSA Class Fund (for FLSA claims by FLSA opt-ins)

Question 5

How Will My Settlement Payment Be Calculated?

Accepted Answer

If you are eligible and do not opt out, you will receive payment based on
Defendants’ payroll and timekeeping records and the allocation plan approved by
the Court.

* If you are a member of the Virginia Wage Class, you will receive a pro rata
   share of the Virginia Wage Class Fund.
 * If you are a member of the Breach of Contract Class, you will receive a pro
   rata share of the Breach of Contract Class Fund.
 * If you are an FLSA opt-in (i.e., you filed a Consent Form), you will receive
   a pro rata share of the FLSA Class Fund.

Your Notice Packet will include an individualized estimate of your payment based
on Defendants’ records.

FAQs

Basic Information

Basic Information

1. What is This Case About?

2. What is a Class Action and a Collective Action?

3. Am I Included in the Settlement?

4. What Are the Terms of the Settlement?

5. How Will My Settlement Payment Be Calculated?

6. How and When Will I Get Paid?

7. What are My Options?

8. What Claims Am I Releasing if I Stay in the Settlement?

9. What Fees, Costs, and Service Awards Will Class Counsel Request?

10. When Will the Court Decide Whether to Approve the Settlement?

11. If I Exclude Myself from the Settlement, Can I Get Money from This Settlement?

12. If I Am a Current Employee, Will I Experience Any Retaliation or Discrimination?

13. Where Can I Get More Information?