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IF YOU WERE AN EMPLOYEE AT NUGGET MARKET, INC. (“DEFENDANT”) DURING THE PERIOD OF FEBRUARY 3, 2012, THROUGH DECEMBER 9, 2016, YOU MAY BE ABLE TO COLLECT MONEY FROM A CLASS-ACTION SETTLEMENT.

This lawsuit alleges claims for Defendant’s failure to properly calculate the regular rate for overtime; failure to provide meal and rest periods, and to properly provide premium pay in lieu thereof; waiting-time penalties for untimely final pay; improper and/or inaccurate wage statements; unfair business practices; and claims for interest, attorneys’ fees, and costs.

Defendant denies any liability or wrongdoing of any kind associated with the claims alleged in the Action; disputes the damages and penalties claimed by the Class Representative; and further contends that, for any purpose other than settlement, the Action is not appropriate for class- or representative-action treatment.

The proposed settlement provides for a cash payment by Defendant of $2,000,000.00 to fully and finally resolve all claims in the lawsuit (referred to as the “Maximum Settlement Amount”). The total amount to be distributed to class members who can be located and who do not exclude themselves from the settlement will be the value of the Maximum Settlement Amount after deducting the following (the “Net Settlement Amount”): (a) settlement-administration costs not to exceed $31,500.00; (b) a class-representative service award to Plaintiff Martin Coletti not to exceed $10,000.00 for his work and efforts in prosecuting this case, and for undertaking the risks of costs (in the event the outcome of this lawsuit was not favorable); (c) Class Counsel’s attorneys’ fees not to exceed $600,000.00; (d) Class Counsel’s actual litigation costs and expenses as supported by declaration; (e) Defendant’s share of payroll taxes; and (f) payment of $37,500.00 to the Labor and Workforce Development Agency, as required by statute, from the $50,000.00 allocated to the Labor Code Private Attorneys General Act claim. Class Counsel’s attorneys’ fees and costs, and Plaintiff’s class-representative service award remain subject to Court approval.


Settlement Administrator Contact Information:

Coletti v. Nugget Market, Inc.

c/o Rust Consulting, Inc. - 5605

PO Box 2396

Faribault, MN 55021-9096

Toll-Free Phone Number: (888) 398-8208

Fax Number: (866) 591-7255

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