Order: LAWSON ET AL VS TWOMAGNETS INC.

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                                1     ASHKAN SHAKOURI (S.B. #242072)
                          ash@shakourilawfirm.com
                    2     SHAKOURI LAW FIRM
                    3     11601 Wilshire Blvd., Fifth Floor
                          Los Angeles, California 90025
                    4     Telephone:        (310) 575-1827
                          Facsimile:        (310) 575-1872
                    5
                          Attorneys for Plaintiffs
                    6     Lakisha Lawson and Nahrain Karam
                    7
                    8     ADAM J. KARR (S.B. #212288)
                          akarr@omm.com
                    9     ANDREW LICHTENSTEIN (S.B. #279297)
                          alichtenstein@omm.com
                   10     ALLISON BADER (S.B. #324306)
                   11     abader@omm.com
                          O’MELVENY & MYERS LLP
                   12     400 South Hope Street, 18th Floor
                          Los Angeles, CA 90071-2899
                   13     Telephone:        (213) 430-6000
                          Facsimile:        (213) 430-6407
                   14
                   15     Attorneys for Defendant
                          Twomagnets Inc.
                   16
                   17                     IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
                   18                                                   COUNTY OF KERN
                   19
                   20     LAKISHA LAWSON, NAHRAIN KARAM,                                Case No. BCV-21-102508
                          on behalf of themselves and others similarly
                   21     situated,                                                     [PROPOSED] ORDER AMENDING
                                                                                        PROCESS FOR PROVIDING NOTICE
                   22                                                                   OF CLASS AND REPRESENTATIVE
                                                      Plaintiffs,                       ACTION SETTLEMENT AND
                   23                                                                   CONTINUE FINAL APPROVAL
                                                                                        HEARING
                   24                        v.
                                                                                        Honorable Judge J. Eric Bradshaw
                   25     TWOMAGNETS INC., and DOES 1-20,                               Division J
                          inclusive
                   26                                                                   Trial Date: Not Set
                                                      Defendants.                       Action Filed: January 27, 2021
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                    1                                                 [PROPOSED] ORDER
                    2              Plaintiffs Lakisha Lawson and Nahrain Karam (together, “Plaintiffs”) and Defendant
                    3     Twomagnets Inc.’s (“Defendant”) (collectively, with Plaintiffs, the “Parties”) Joint Ex Parte
                    4     Application to Amend Process for Providing Notice of Class and Representative Action Settlement

                    5     and Continue Final Approval Hearing came on for hearing before this Court on July 20, 2022.
                    6     After consideration of the papers submitted by the parties, the pleadings in this case, as well as
                    7     argument and other matters properly submitted to the Court, and good cause appearing therefore:
                    8              IT IS HEREBY ORDERED that the Parties’ Joint Ex Parte Application is GRANTED, as

                    9     follows:
                   10          •   The Court approves the following changes proposed by the Parties for providing notice of
                   11              the Parties’ Class and Representative Action Settlement:
                   12                   o    Each Settlement Class Member whose social security number remains unknown
                   13                       will receive, enclosed with the Settlement Notice already approved by this Court, a
                   14                       letter from the Claims Administrator stating that the Settlement Class Member will
                   15                       need to provide their social security number to the Claims Administrator to receive a
                   16                       settlement check;
                   17                   o    The Claims Administrator’s letter will also include instructions on how the
                   18                       Settlement Class Members who receive this letter can provide their social security
                   19                       numbers to the Claims Administrator, which will include the option of completing
                   20                       and returning to the Claims Administrator a Form W-9, which will also be enclosed;
                   21                   o    The letter will also explain that if the Settlement Class Members who receive the
                   22                       letter do not provide their social security numbers and, as a result, do not receive
                   23                       settlement checks, they will still be bound by the release of class claims in the
                   24                       Settlement (the “Class Release”), unless they timely submit a proper request for
                   25                       exclusion from the Settlement, and will still be bound by the release of PAGA
                   26                       claims in the Settlement (the “PAGA Release”), if applicable, regardless of whether
                   27                       they file a request for exclusion;
                   28                   o    In addition to sending the Settlement Notice and the enclosed letter and Form W-9
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                    1                       via U.S. mail, as provided by the Settlement, the Claims Administrator will also
                    2                       send them via e-mail to ensure the best possibility of notice under the
                    3                       circumstances;
                    4                   o    Settlement Class Members who receive the letter and Form W-9 described above

                    5                       will have until the Response Deadline, which is defined in the Settlement
                    6                       Agreement as forty-five (45) calendar days from the date of mailing of the
                    7                       Settlement Notice, to provide their social security numbers to the Claims
                    8                       Administrator;

                    9                   o    The Claims Administrator will use the social security numbers of Settlement Class
                   10                       Members only for the purpose of administering the Settlement and will maintain the
                   11                       social security numbers securely and in a manner that protects them from disclosure;
                   12                   o    Any settlement amounts allocated to Settlement Class Members that cannot be paid
                   13                       to them because their social security numbers remain unknown after the conclusion
                   14                       of the process described above will be added pro-rata to the settlement payments
                   15                       made to Settlement Class Members whose social security numbers are known; and
                   16                   o    Any Settlement Class Members who do not receive settlement checks because their
                   17                       social security numbers remain unknown after the process described above will still
                   18                       be bound by the Class Release, unless they timely and properly requested exclusion
                   19                       from the Settlement, and will still be bound by the PAGA Release, if applicable,
                   20                       regardless of whether they timely and properly requested exclusion from the
                   21                       Settlement; and
                   22          •   The Final Approval Hearing is continued from September 27, 2022, at 8:30 a.m., to
                   23              ____________________, 2022, at _______ _.m.
                   24              IT IS SO ORDERED.
                   25
                          Dated:   _______________________
                   26                                                           Honorable Judge J. Eric Bradshaw
                                                                                Judge of the Superior Court
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