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If you performed at Imperial Showgirls in Anaheim, California, at any time from August 5, 2014,
through November 30, 2018, this proposed class action settlement may affect your rights.
What is this Lawsuit About?
This Lawsuit is about whether Defendant(s) misclassified exotic dance entertainers as independent contractors, paid minimum
and overtime wages for all hours worked, provided proper meal periods and rest periods, provided proper wage statements, paid
all wages owed upon termination of employment, kept accurate records for hours work, reimbursed performers for business expenses,
made improper deductions from wages, and permitted performers to retain all gratuities as required by applicable federal
and California laws, and whether certain penalties are due under the California Private Attorneys General Act (“PAGA”).
Throughout the litigation, Defendants have denied—and continue to deny—the factual and legal allegations in the case and have
maintained that they have valid defenses to the claims. Defendants deny any wrongdoing and assert that their pay practices at
all times complied with the law. Defendants also deny that they owe the monies claimed in the lawsuit. Yet Defendants have voluntarily
agreed to the terms of a negotiated settlement to avoid the burden and expense of continued litigation.
Am I part of this Class?
The “Class” includes: All exotic dancers who performed at Imperial Showgirls in Anaheim, California, at any time from August 5,
2014, through November 30, 2018.
What are the terms of the proposed Settlement?
Defendants have agreed to pay $2,500,000.00 to settle all claims made in this Lawsuit. This amount is also known as the
“Gross Settlement Amount.”
If the Court approves each of the requested deductions from the Gross Settlement Amount, the Parties estimate there will be
about $1,484,666.67 remaining. The remaining funds will be called the “Net Settlement Amount.” The Net Settlement Amount
will be distributed to Class Members who do not request exclusion (the “Participating Class Members”) according to the
following formula (the “Individual Settlement Payments”):
The Net Settlement Amount will be distributed to each Participating Class Member on a pro rata basis determined by the
number of Qualifying Months each Participating Class Member performed at Imperial Showgirls during the Class Period. The Settlement
Administrator shall disperse Individual Class Member Settlement Payments to Participating Class Members in accordance
with the terms of the Settlement.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT
PARTICIPATE IN THE SETTLEMENT – ACTION REQUIRED
Stay in this Lawsuit. Receive a payment. Give up certain rights. You MUST FILL OUT THE ONLINE W-9 Form.
If the Settlement Administrator does not have your correct address and Social Security Number, you will not receive an Individual
Settlement Payment and the funds allocated to you will be redistributed to other Class Members. Please see
FAQ 18 for further details.
OBJECT TO THE SETTLEMENT
Stay in this Lawsuit. May give up certain rights. If you object to
the Settlement, you will remain a member of the Settlement Class,
and if the Court approves the Settlement, you will be bound under the
Settlement just as Class Members who do not object, including the
release of rights to sue the Defendants separately for the Released
Class Claims.
ASK TO BE EXCLUDED
Get out of the Class Settlement. Get no payment from the Class
Settlement but still get payment from the PAGA Settlement.
Keep rights. If you ask to be excluded from the Settlement, you
won’t receive any payment from the Class Settlement. But you keep
any rights to sue Defendants separately for the legal claims raised or
that could have been raised in this Lawsuit. But you will still receive a
payment from the PAGA Settlement and release the PAGA claims.