A proposed settlement has been reached in a class action lawsuit called Jane Doe, et al. v MasterCorp., Inc., Case No. 1:24-cv-00678 (E.D. Va.) (the “Settlement”). The Settlement is between Jane DoeJohn Doe 1, and John Doe 2 (collectively “Plaintiffs”), on behalf of the proposed Settlement Class, and MasterCorp., Inc. (“MasterCorp” or “Defendant”). This Notice summarizes your rights and options. More details are available at www.ColombianHousekeeperSettlement.com.

Am I part of the Settlement Class?

You are a Settlement Class Member if:

  • You are a Colombian National or of Colombian origin;
  • You were paid by Perennial Pete, LLC or one of its affiliated entities or companies, including SM Cleaning Solutions Inc.; WD Cleaning Solutions Inc.; DM Cleaning Solutions Inc.; JM Cleaning Solutions Inc.; EV Cleaning Solutions Inc.; EM Cleaning Services and Solutions Inc.; SD Cleaning Services and Solutions Inc.; and
  • You provided housekeeping services at resorts in the United States where MasterCorp was responsible for housekeeping between March 19, 2021 and May 15, 2024.

What is this lawsuit about?

Plaintiffs claim that MasterCorp subjected Settlement Class Members to unfair and unlawful practices. These included working Settlement Class Members for long hours without overtime pay, and immigration-related misconduct that made Settlement Class Members vulnerable. MasterCorp denies these claims. The Court has not decided who is right or wrong. The parties have agreed to the Settlement to avoid the risks, uncertainty, expense, and burden of litigation.

What does the Settlement provide?

Settlement Class Members who file a valid and timely claim will receive an equal share of the $4,950,000 USD Settlement Amount less attorneys’ fees and litigation costs, service awards, settlement administration costs, and any applicable taxes (“NET Settlement Amount”).

There are an estimated 205 Settlement Class Members. If all 205 file a claim, they will each receive 1/205 of the NET Settlement Amount. If fewer Class Members file a claim, payments will increase equally on a pro rata share, up to a maximum of 1/50 of the NET Settlement Amount. Any remaining funds will be distributed to St. Jude for undocumented-immigrant-related services.

How can I get a payment?

You must complete and submit a timely Claim Form online at www.ColombianHousekeeperSettlement.com or mailed postmarked by August 13, 2024  to: Colombian Housekeeper Settlementc/o JND Legal AdministrationPO Box 91308Seattle WA 98111. If you do not submit a valid Claim Form by August 13, 2024, you will not receive a payment, but you will be bound by the Court’s judgment.

What are my other options?

1) Do nothing. Receive no payment. Be bound by the Court’s decision. Give up your right to sue or continue to sue MasterCorp for the claims in this case.

2) Exclude yourself (“Opt Out”). Remove yourself from the Settlement Class and receive no payment. This is the only option that allows you to keep your right to sue or continue to sue MasterCorp for the claims in this case.

3) Object. Tell the Court what you do not like about the Settlement. You will still be bound by the Settlement, and you may still file a claim.

The deadline to exclude yourself or object is August 13, 2024. For more details about your rights and options and how to exclude yourself or object, visit www.ColombianHousekeeperSettlement.com.

What happens next?

The Court will hold a Final Approval Hearing on September 20, 2024 to consider whether to give final approval to the Settlement and grant Class Counsel’s request for attorneys’ fees and litigation costs not to exceed one third of the Settlement Amount plus reasonable costs; service awards to Plaintiffs at a maximum amount of $7,500 in U.S. dollars each; as well as reimbursement for expenses incurred for settlement administration, including notice and taxes. The Court appointed Rachel Geman from Lieff, Cabraser, Heimann & Bernstein, LLP and Mark Hanna from Murphy Anderson PLLC as Class Counsel. You will not be charged for these lawyers. You do not need to attend the hearing, but you are welcome to attend at your own expense.

How do I get more information?

Visit www.ColombianHousekeeperSettlement.com or call 1-888-825-1238 (from U.S.) or 01-800-519-1529 (from Colombia).

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