Frequently Asked Questions

1. What is the Action about?

Plaintiffs are several people formerly employed by FNL or its predecessor or formerly placed to work at FNL or its predecessor by staffing agencies. The Action accuses FNL and/or its staffing agencies of violating California laws by failing to pay all overtime wages; failing to pay all overtime wages at required rates; failing to pay minimum wages; failing to timely pay wages during work or upon termination; failing to reimburse expenses; failing to provide required meal periods or rest breaks; failing to provide accurate itemized wage statements; failing to provide sick days and sick pay; failing to provide suitable seating; and failing to maintain suitable temperatures. Based on the same claims, Plaintiffs have also asserted a claim for civil penalties under the California Private Attorneys General Act (Labor Code §§ 2698, et seq.) ("PAGA"). Plaintiff is represented by attorneys in the Action: Joseph Lavi and Vincent Granberry of Lavi & Ebrahimian, LLP; Marcus Bradley, Kiley Grombacher, and Lirit King of Bradley/Grombacher, LLP; Emil Davtyan, David Yeremian, David Keledjian, and David Arakelyan of D. Law, Inc.; Michael Nourmand and James A. De Sario of The Nourmand Law Firm, APC (collectively, "Class Counsel").

FNL strongly denies violating any laws or failing to pay any wages and contends it complied with all applicable laws.

2. What does it mean that the Action has settled?

So far, the Court has made no determination whether FNL or Plaintiffs are correct on the merits. In the meantime, Plaintiffs and FNL hired a retired judge in an effort to resolve their disputes by settling rather than continuing the expensive and time-consuming process of litigation. The negotiations were successful. Plaintiffs and FNL have negotiated and signed a written Settlement Agreement 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, FNL 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) FNL 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 and PAGA Members. The Court preliminarily approved the proposed Settlement as fair, reasonable and adequate, authorized the Notice, and scheduled a hearing to determine Final Approval.

3. What are the important terms of the proposed Settlement?

1. FNL Will Pay Five Million Five Hundred Sixty-Five Thousand Dollars and Zero Cents ($5,565,000.00) as the Gross Settlement Amount. FNL has agreed to deposit the Gross Settlement Amount into an account controlled by the Settlement Administrator of the Settlement. The Settlement Administrator will use the Gross Settlement Amount to pay the Individual Class Payments, Individual PAGA Payments, Class Representative Enhancement Payments, Class Counsel's attorney's fees and expenses, the Settlement Administrator's expenses, and penalties to be paid to the California Labor and Workforce Development Agency ("LWDA"). Assuming the Court grants Final Approval, FNL will fund the Gross Settlement not more than thirty (30) days after the Judgment entered by the Court becomes final. The Judgment will be final after expiration of the time for appealing the Judgment, or a later date if the Judgment is appealed.
2. Court Approved Deductions from Gross Settlement Amount. At the Final Approval Hearing, Plaintiff and/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement Amount, the amounts of which will be decided by the Court at the Final Approval Hearing:
   1. Up to One Million Nine Hundred Forty-Seven Thousand Seven Hundred Fifty Dollars and No Cents ($1,947,750.00) (35% of the Gross Settlement Amount) to Class Counsel for attorneys' fees and up to Fifty-Two Thousand Two Hundred Fifty Dollars and No Cents ($52,250.00) for their litigation expenses. To date, Class Counsel has worked and incurred expenses on the Action without payment.
   2. Up to Ten Thousand Dollars and No Cents ($10,000.00) to each Plaintiff as a Class Representative Enhancement Payment for filing the Action, working with Class Counsel and representing the Settlement Class. These are the only amounts Plaintiffs will receive other than each Plaintiff's Individual Class Payment and any Individual PAGA Payment.
   3. Up to Thirty-Two Thousand Dollars and No Cents ($32,000.00) to the Settlement Administrator for services administering the Settlement.
   4. Up to Two Hundred Thousand Dollars and No Cents ($200,000.00) for PAGA Penalties, allocated 75% to the LWDA and 25% in Individual PAGA Payments to the PAGA Members based on the pay periods they worked during the PAGA Period.

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 Settlement Administrator will distribute the rest of the Gross Settlement Amount (the "Net Settlement Amount") by making Individual Class Payments to Participating Class Members based on their workweeks during the class period.

4. Taxes Owed on Payments to Class Members. Plaintiffs and FNL are asking the Court to approve an allocation of 20% of each Individual Class Payment to taxable wages ("Wage Portion") and 80% to interest and penalties ("Non-Wage Portion"). The Wage Portion is subject to withholdings and will be reported on IRS W-2 Forms. FNL will separately pay employer payroll taxes it owes on the Wage Portion. The Individual PAGA Payments are counted as penalties rather than wages for tax purposes. The Settlement Administrator will report the Individual PAGA Payments and the Non-Wage Portions of the Individual Class Payments on IRS 1099 Forms.

   Although Plaintiffs and FNL 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 on back taxes) 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.

5. Need to Promptly Cash Payment Checks. The front of every check issued for Individual Class Payments and Individual PAGA Payments will show the date when the check expires (the void date). If you don't cash it by the void date, your check will be automatically cancelled, and the monies will be deposited with the California Controller's Unclaimed Property Fund in your name.

   If the monies represented by your check is sent to the Controller's Unclaimed Property Fund, you should consult the rules of the Fund for instructions on how to retrieve your money.

6. 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 Settlement Administrator in writing, not later than October 26, 2026, that you wish to opt out. The easiest way to notify the Settlement Administrator is to send a written and signed Request for Exclusion by the October 26, 2026 Response Deadline. The Request for Exclusion must be a letter or post card that: (1) contains the name, address, telephone number and the last four digits of the Social Security number of the Class Member; (2) contains a statement that the Class Member wishes to be excluded from the Settlement Class; (3) is signed by the Class Member; and (4) is postmarked by October 26, 2026, and mailed to the Settlement Administrator. Excluded Settlement Class Members (i.e., Non-Participating Class Members) will not receive Individual Class Payments but will preserve their rights to personally pursue wage and hour claims against FNL, subject to its defenses.

   You cannot opt out of the PAGA portion of the Settlement. Class Members who exclude themselves from the Class Settlement remain eligible for Individual PAGA Payments and are required to give up their right to assert PAGA claims against the Released Parties, as described in Question 10.

7. 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 enter a Judgment. It is also possible the Court will enter a Judgment that is reversed on appeal or that the Settlement does not become final for other reasons. Plaintiffs and FNL have agreed that in such cases, the Settlement will be void: FNL will not pay any money and Class Members will not release any claims.
8. Settlement Administrator. The Court has appointed a neutral company, Simpluris, Inc. (the "Settlement Administrator") to send the Notice, calculate and make payments, and process Class Members' Requests for Exclusion. The Settlement Administrator will also decide Class Member Challenges over workweeks or pay periods, mail and re-mail settlement checks and tax forms, and perform other tasks necessary to administer the Settlement. The Settlement Administrator's contact information is contained in Question 9.

9. Participating Class Members' Release. After the Judgment is final and FNL has fully funded the Gross Settlement Amount 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 opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against the Released Parties for the Released Claims.

   The Participating Class Members will be bound by the following release:

   The "Released Parties" are the following: (a) Defendant and any temporary or staffing agencies (including but not limited to Adecco, Bluecrew, Personal HR, Randstad, Next Level Staffing, IWC, Compliant Care Staffing, Driven Talent, and Eastridge) which provided any Class Members or PAGA Members for Defendant; (b) the respective former and present parents (including but not limited to Fashion Nova LLC), subsidiaries, affiliated corporations and entities, clients, vendors and independent contractors of the entities identified in subparagraph (a); (c) the successors and predecessors of the entities identified in subparagraphs (a) and (b); and (d) each of the respective current, former, and future officers, directors, members, managers, insurers, accountants, attorneys, investment bankers, trusts, trustees, licensors, licensees, employees, consultants, vendors, payroll companies, independent contractors, clients, partners, shareholders, joint venturers, and third-party agents of any entities identified in subparagraphs (a) through (c).

   Plaintiffs and all Participating Class Members, on behalf of themselves, their heirs, executors, administrators, attorneys, agents, assigns, and any entities or businesses in which any of them have a controlling ownership interest, release and discharge the Released Parties from all state, federal, or local claims, rights, demands, liabilities, and causes of action alleged in the Amended Complaint, or that could have been asserted based on any facts alleged in the Amended Complaint, including but not limited to violations of California Labor Code sections 201, 202, 203, 204, 206, 210, 215, 216, 218, 218.5, 218.6, 221, 223, 225, 225.5, 226, 226.3, 226.6, 226.7, 233, 246, 246.5, 354, 408, 500, 510, 512, 515, 516, 553, 558, 558.1, 1174, 1174.5, 1175, 1182, 1182.11, 1182.12, 1185, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2802, 6720; California Business and Professions Code sections 17200, et seq.; California Civil Code sections 3287, 3289; California Code of Civil Procedure section 1021.5; and applicable Industrial Welfare Commission Wage Orders, and claims for failure to pay minimum wages and overtime wages, including any overtime wages owed on bonuses, incentive pay, or other such compensation; failure to pay wages for all hours worked, including for off the clock work; failure to provide meal periods; failure to pay meal period premium wages; failure to provide rest periods; failure to pay rest period premium wages; failure to reimburse for necessary business expenditures; failure to pay all wages due; failure to furnish complete, accurate, itemized wage statements; failure to pay all earned wages timely during employment and at termination; failure to maintain accurate records; failure to provide sick leave; failure to pay sick leave, including sick leave owed on bonuses, incentive pay, or other such compensation; failure to maintain temperature providing reasonable comfort; failure to adopt standards that minimize excessive indoor heat; and failure to provide suitable seating (the "Class Released Claims"). Except as set forth in this paragraph and the paragraph below, Participating Class Members do not release any other claims, including claims for vested benefits, 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.

10. PAGA Members' Release. After the Court's judgment is final and FNL has paid the Gross Settlement and separately paid the employer-side payroll taxes, all PAGA Members will be barred from asserting PAGA claims against the Released Parties, whether or not they exclude themselves from the Settlement. This means that all Released Parties, including those who are Participating Class Members and those who opt out of the class part of the Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against the Released Parties for the released claims described below.

    Plaintiffs and all PAGA Members, on behalf of themselves, their heirs, executors, administrators, attorneys, agents, assigns, and any entities or businesses in which any of them have a controlling ownership interest, and the State of California, release and forever discharge the Released Parties from all claims, demands, rights, liabilities and causes of action for civil penalties under California Labor Code Private Attorneys General Act of 2004 (Labor Code section 2698 et seq.) alleged in the Amended Complaint, or that could have been asserted based on any facts ever alleged in the Amended Complaint or any LWDA notices related to any of the Actions, including but not limited to violations of California Labor Code sections 201, 202, 203, 204, 206, 210, 215, 216, 218, 218.5, 218.6, 221, 223, 225, 225.5, 226, 226.3, 226.6, 226.7, 233, 246, 246.5, 354, 408, 500, 510, 512, 515, 516, 553, 558, 558.1, 1174, 1174.5, 1175, 1182, 1182.11, 1182.12, 1185, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2802, 6720, and applicable Industrial Welfare Commission Wage Orders, and claims for failure to pay minimum wages and overtime wages, including any overtime wages owed on bonuses, incentive pay, or other such compensation; failure to pay wages for all hours worked, including for off the clock work; failure to provide meal periods; failure to pay meal period premium wages; failure to provide rest periods; failure to pay rest period premium wages; failure to reimburse for necessary business expenditures; failure to pay all wages due; failure to furnish complete, accurate, itemized wage statements; failure to pay all earned wages timely during employment and at termination; and failure to maintain accurate records; failure to provide sick leave; failure to pay sick leave, including sick leave owed on bonuses, incentive pay, or other such compensation; failure to maintain temperature providing reasonable comfort; failure to adopt standards that minimize excessive indoor heat; and failure to provide suitable seating (the "PAGA Released Claims"). The PAGA Released Claims do not include the claims related to suitable temperature that have been resolved through a settlement in the case of Hill v. Fashion Nova et al., Los Angeles Superior Court Case No. 21STCV40012.

4. How will the Settlement Administrator calculate my payment?

1. Individual Class Payments. The Settlement Administrator will calculate Individual Class Payments by (a) dividing the Net Settlement Amount by the total number of workweeks worked by all Participating Class Members during the Class Period, and (b) multiplying the result by the number of workweeks worked by each individual Participating Class Member.
2. Individual PAGA Payments. The Settlement Administrator will calculate Individual PAGA Payments by (a) dividing $50,000.00 by the total number of pay periods worked by all PAGA Members during the PAGA Period and (b) multiplying the result by the total number of such pay periods worked by each individual PAGA Member.

3. Workweek/Pay Period Challenges. The number of workweeks you worked during the Class Period and the number of pay periods you worked during the PAGA Period, as recorded in the records of FNL or the staffing agencies are stated in the first page of the Notice. You have until October 26, 2026, to challenge the number of workweeks and/or pay periods credited to you. You can submit your challenge by signing and sending a letter to the Settlement Administrator via mail, email or fax. Question 9 below has the Settlement Administrator's contact information.

   You need to support your challenge by sending copies of pay stubs or other records. The Settlement Administrator will accept FNL's and the staffing agencies' calculation of workweeks and/or pay periods based on their 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 Settlement Administrator will resolve workweek and/or pay period challenges based on your submission and on input from Class Counsel (who will advocate on behalf of Participating Class Members and PAGA Members) and FNL's counsel. The Settlement Administrator's decision is final. You can't appeal or otherwise challenge its final decision.

5. How will I get paid?

1. Participating Class Members. The Settlement 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) including those who also qualify as PAGA Members. The single check will combine the Individual Class Payment and the Individual PAGA Payment.
2. Non-Participating Class Members. The Settlement Administrator will send, by U.S. mail, a single Individual PAGA Payment check to every PAGA Member who opts out of the Class Settlement (i.e., every Non-Participating Class Member).

Your check will be sent to the same address as the Notice. If you change your address, be sure to notify the Settlement Administrator as soon as possible. Question 9 below has the Settlement Administrator's contact information.

6. How do I opt out of the Class Settlement?

Submit a written and signed postcard or letter that must: (1) contain the name, address, telephone number and the last four digits of the Social Security number of the Class Member; (2) contain a statement that the Class Member wishes to be excluded from the Settlement Class; (3) be signed by the Class Member. You must make the request yourself. If someone else makes the request for you, it will not be valid. The Settlement Administrator must be sent your request to be excluded by October 26, 2026, or it will be invalid. Question 9 below has the Settlement 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 FNL are asking the Court to approve. On September 25, 2026, Class Counsel and Plaintiffs 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 Enhancement Payments stating (i) the amount Class Counsel is requesting for attorneys' fees and litigation expenses; and (ii) the amount Plaintiffs are requesting as Class Representative Enhancement Payments.

Upon reasonable request, Class Counsel (whose contact information is in Question 9) will send you copies of these documents at no cost to you. You can also view them on this website 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 Settlement, the Motion for Final Approval and/or Motion for Fees, Litigation Expenses and Enhancement Payments 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 Settlement Administrator is October 26, 2026. Be sure to tell the Settlement Administrator what you object to, why you object, and any facts that support your objection. Make sure you identify the Action and include your name, current address, telephone number, and approximate dates of employment and sign the objection. Question 9 below has the Settlement 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 object to, why you object, and any facts that support your objection. See Question 8 (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 December 1, 2026 at 9:00 a.m. in Department 6 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 Amount will be paid to Class Counsel, Plaintiffs, and the Settlement Administrator. The Court will invite comment from objectors, Class Counsel and Defense Counsel before making a decision. You can attend (or hire a lawyer to attend) either personally or virtually via LACourtConnect https://www.lacourt.ca.gov/pages/lp/lacc-welcome. Check the Court's website for the most current information.

It's possible the Court will reschedule the Final Approval Hearing. You should check this website beforehand or contact Class Counsel to verify the date and time of the Final Approval Hearing.

9. How can I get more information?

The Settlement Agreement sets forth everything FNL and Plaintiffs have promised to do under the proposed Settlement. The easiest way to read the Settlement Agreement, the Judgment or any other Settlement documents is on the Important Documents page. You can also telephone or send an email to Class Counsel or the Settlement Administrator using the contact information listed below or consult the Superior Court website by going to https://www.lacourt.ca.gov/pages/lp/access-a-case/tp/find-case-information and entering the Case Number for the Action, Case No. 22STCV26948. 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.

10. What if I lose my Settlement check?

If you lose or misplace your settlement check before cashing it, the Settlement 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 for instructions on how to retrieve the funds.

11. What if I change my address?

To receive your check, you should immediately notify the Settlement Administrator if you move or otherwise change your mailing address.