Judge: Curtis A. Kin, Case: 20STCV22269, Date: 2022-12-22 Tentative Ruling
Case Number: 20STCV22269 Hearing Date: December 22, 2022 Dept: 72
MOTION FOR PRELIMINARY APPROVAL
OF CLASS SETTLEMENT
Date: 12/22/22
(8:30 AM)
Case: Luis Garcia v. Car Aroma
Supplies, Inc. (20STCV22269)
TENTATIVE RULING:
Plaintiff Luis Garcia’s Motion for Preliminary Approval of
Class Settlement is CONTINUED.
In reviewing the proposed Settlement Agreement, the court
has the following concerns:
- Defendant will fund the
Gross Settlement Amount in two installments: 1) an initial installment of
$112,500 to be paid on the later of 30 days after final approval or 12
months from “today” and 2) $112,500 six months after the initial payment.
(Settlement ¶ 3.17.) No payments to Class Members shall be made
before the Gross Settlement Amount is fully funded. (Settlement ¶ 3.17.) The
word “today” is ambiguous. It is unclear whether “today” refers to day
plaintiff signed the Settlement Agreement (4/20/22), defendant signed the
Settlement (6/20/22), or some other day. If “today” refers to some other
day on or after the hearing on the instant motion, it is questionable
whether it is fair, adequate, and reasonable for the funding of the
settlement to begin at the earliest a year from the instant hearing.
- The failure to send a
written objection does not preclude any Class Member from objecting for
the first time at the final approval hearing. (Settlement ¶ 3.15.) The Notice
of Settlement of Class Action (“Notice”) does not inform Class Members who
do not submit written objections of the right to appear at the final
approval hearing.
- The Individual Settlement
Payment Formula referenced in Paragraph 3.19 is located in paragraph 3.20,
not paragraph 3.21 of the Settlement.
- To determine the Class
Weekly Amount, as opposed to the PAGA Weekly Amount, the Settlement
Administrator divides the “Net Settlement Amount” by the total number of
workweeks Participating Class Members worked during the Class Period.
(Settlement ¶ 3.20.) However, the “Net Settlement Amount” appears to
include the employee portion of the PAGA Allocation. (Settlement ¶ 1.22.)
The Settlement sets forth a separate formula for the PAGA Weekly Amount.
(Settlement ¶ 3.20.) The Court inquires whether the employee portion of
the PAGA Allocation should be excluded from the definition of “Net
Settlement Amount.”
- An additional 14 days to
mail a Request for Exclusion or a Notice of Objection is provided if a
Notice Packet is re-mailed. (Settlement ¶ 3.11.) The Court inquires why
there is no similar extension for a Class Member to dispute the number of
workweeks indicated by the Settlement Administrator. (Settlement ¶ 3.13.)
- The Settlement Agreement
does not specify what happens if a Settlement Class Member submits a valid
Request for Exclusion and a Notice of Objection. (Settlement ¶ 3.14.) The
Settlement Agreement does not state which document takes precedence.
- In the explanation of the
release in the Notice of Settlement of Class Action, the notice states
that the Complaint is operative. The First Amended Complaint is the
operative pleading.
- The Notice states that the
attached Form A is the Request for Exclusion and the attached Form B is an
objection form. The Request for Exclusion form attached as Exhibit C to
counsel’s declaration is not labeled Form A. The objection form was not
attached to the Notice or counsel’s declaration. A Class Member receiving
the Notice may have difficulty identifying the documents as labeled in the
Notice.
Plaintiff is ordered to provide supplemental briefing or
other documents (which may include, among other things, an Amended Stipulation to
Class Settlement and Release) addressing the above concerns by no later than
______________. The Motion for Preliminary Approval of Class Settlement is CONTINUED
to ____________ at _______ in Department 72 (Stanley Mosk Courthouse).