Dotts v. Jefferson Crest LLC et al

Filing 46

ORDER signed by Judge J.P. Stadtmueller on 5/14/2018. 43 Parties' Original Joint Motion for Approval of Settlement Agreement DENIED as moot. 45 Parties' Amended Joint Motion for Approval of Settlement Agreement GRANTED. Parties 9; Settlement Agreement (Docket #43-1) and Addendum thereto (Docket #45-1) APPROVED; Defendants to MAKE payments as set forth. Plaintiffs AWARDED attorney's fees and costs in the amount of $40,000.00; Defendants to MAKE payments as set fo rth. Failure to cure breach regarding payments to be DEEMED a failure to comply with this Mandatory Injunction. This Court to RETAIN jurisdiction for purposes of enforcing terms of the Settlement Agreement and this Mandatory Injunction. Except as otherwise provided, CASE DISMISSED with prejudice and without further costs to any party. See Order for further details. (cc: all counsel) (jm)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN SHATAWAN DOTTS, on behalf of herself and all others similarly situated, Plaintiffs, Case No. 17-CV-1092-JPS v. JEFFERSON CREST, LLC and DANIEL E. TAYLOR, ORDER Defendants. On May 4, 2018, the parties filed an amended joint motion for approval of their settlement agreement resolving Plaintiffs’ Fair Labor Standards Act and Wisconsin wage and hour law claims against Defendants, including the claims stated in the complaint and additional claims not included in the complaint but uncovered through discovery and investigation into this matter. (Docket #45).1 After reviewing the terms of the settlement agreement, (Docket #43-1), and the addendum thereto relating to this Court’s retention of jurisdiction, (Docket #45-1),2 the Court finds the parties’ settlement constitutes “a fair and reasonable resolution of [] bona fide dispute[s]” under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., and Wisconsin law, Lynn Food Stores, Inc. v. United States, 679 F.2d 1350, 1355 (11th Cir. 1982); Walton v. United Consumers Club, Inc., 786 Shatawan Dotts is the only named plaintiff, but many others have opted into the lawsuit since the Court conditionally certified it as a collective action. (Docket #14). 1 The parties’ original motion for approval of their settlement requested that the Court retain jurisdiction over this matter if the need to enforce the settlement arose, but the proposed order did not comply with Seventh Circuit precedent on that question. The amended motion rectifies this error. 2 F.2d 303, 306 (7th Cir. 1986). As such, the Court will approve the parties’ settlement agreement. Further, as requested, the Court will award Plaintiffs their attorney’s fees and costs in the amount of $40,000.00, as the evidence submitted in connection with the parties’ motion shows that the fees and costs sought were reasonably incurred. See (Docket #44). Finally, as requested, the Court will dismiss this action with prejudice and without taxing costs to either party, while retaining jurisdiction over this matter for potential enforcement of the settlement agreement pursuant to Kokkonen v. Guardian Life Insurance Company of America, 511 U.S. 375 (1994). Accordingly, IT IS ORDERED that the parties’ original joint motion for approval of the settlement agreement (Docket #43) be and the same is hereby DENIED as moot; IT IS FURTHER ORDERED that the parties’ amended joint motion for approval of the settlement agreement (Docket #45) be and the same is hereby GRANTED; IT IS FURTHER ORDERED that the parties’ settlement agreement (Docket #43-1) and addendum thereto (Docket #45-1) be and the same are hereby APPROVED, and the amounts set forth therein shall be paid as provided in the settlement agreement and its exhibits; IT IS FURTHER ORDERED that Plaintiffs are awarded attorney’s fees and costs in the amount of $40,000.00, to be paid as set forth in the settlement agreement and its exhibits; Page 2 of 15 IT IS FURTHER ORDERED that on or before August 15, 2018, Defendants shall make all payments to Plaintiffs according to the following table: Name Service Payment 1099 Current Claim W2 Current Claim 1099 Other Claims W2 Other Claims 1099 Alex Jones $30.60 $30.60 $126.36 $126.36 Amie Golimowski $0.63 $0.63 $6.44 $6.44 Andrew Hardin $1.85 $1.85 $0.00 $0.00 Aquice Collins $5.72 $5.72 $12.26 $12.26 Argo McMorris $30.68 $30.68 $57.01 $57.01 Ashley Jarrell $7.34 $7.34 $23.60 $23.60 Betty Clemons $5.94 $5.94 $15.86 $15.86 Betty Wilks $0.62 $0.62 $19.83 $19.83 Carla Jelks $0.57 $0.57 $1.23 $1.23 Catherine O'Connor $0.00 $0.00 $2.15 $2.15 Charmaine Davenport $7.66 $7.66 $0.00 $0.00 Constance Price $0.00 $0.00 $24.15 $24.15 Crystal Chatman $5.86 $5.86 $0.00 $0.00 Danny Waites $0.00 $0.00 $1.04 $1.04 Darnell Townsell $0.94 $0.94 $10.56 $10.56 Darnisha Walton $0.00 $0.00 $6.26 $6.26 Denise Brown $48.13 $48.13 $71.87 $71.87 Devon Burns $0.57 $0.57 $0.00 $0.00 Erica Dixon $0.00 $0.00 $4.17 $4.17 Evette Clark $0.00 $0.00 $19.31 $19.31 Janae Smith $4.54 $4.54 $8.58 $8.58 Jaquita Green $2.29 $2.29 $5.72 $5.72 Kaneshia Jones $0.98 $0.98 $9.92 $9.92 Karrimetha Walker $1.64 $1.64 $16.70 $16.70 Kathy Townsend $0.16 $0.16 $1.07 $1.07 Kenisha Davis $1.08 $1.08 $8.35 $8.35 Keondra Sanford $1.42 $1.42 $10.73 $10.73 Kiera Thompson $0.00 $0.00 $2.09 $2.09 Kimberly Wright $0.00 $0.00 $1.13 $1.13 Lakesha Barefield $2.11 $2.11 $6.39 $6.39 Lannika Connor $0.00 $0.00 $0.84 $0.84 Laquita Allen $0.15 $0.15 $16.70 $16.70 Page 3 of 15 Latasha Eskridge $0.16 $0.16 $4.41 $4.41 Latonya Parker $7.66 $7.66 $26.84 $26.84 Latrina Kittler $0.32 $0.32 $4.42 $4.42 Lawanda Carter $0.74 $0.74 $8.58 $8.58 Lucille Brawner $10.37 $10.37 $12.52 $12.52 Mi'Laija Hyche $2.43 $2.43 $15.03 $15.03 Monica Lambert $0.34 $0.34 $2.28 $2.28 Monique Grimes $11.73 $11.73 $19.05 $19.05 Natchia Harris $2.38 $2.38 $7.51 $7.51 Octavia Mitchell $0.16 $0.16 $2.20 $2.20 Pinkie Broadway $1.17 $1.17 $9.05 $9.05 Precious Benjamin $33.99 $33.99 $33.85 $33.85 Raven Bishop $11.80 $11.80 $14.34 $14.34 Roshelia Bush $0.00 $0.00 $6.44 $6.44 Schlonda Holifield $0.57 $0.57 $3.31 $3.31 Serenity Armstead $0.00 $0.00 $1.16 $1.16 Shakia Adams $0.15 $0.15 $2.09 $2.09 Shamika Christian $8.58 $8.58 $15.66 $15.66 Shannon Davis $0.15 $0.15 $3.13 $3.13 Sharon Washington $5.11 $5.11 $36.96 $36.96 $14.28 $14.28 $19.83 $19.83 Shauntize Richards $4.31 $4.31 $6.26 $6.26 Star Davis-Stinson $9.19 $9.19 $0.00 $0.00 Tahesha Young $3.31 $3.31 $18.98 $18.98 Takiesha LambMalone $0.57 $0.57 $1.23 $1.23 Talisha Peete $0.44 $0.44 $6.43 $6.43 Taquita Hodges $1.72 $1.72 $5.22 $5.22 Tarrell Hogle $9.65 $9.65 $5.91 $5.91 Tasha Evans $0.69 $0.69 $2.25 $2.25 Tashiana Fleming $4.21 $4.21 $12.52 $12.52 Tatanashana Carter $14.94 $14.94 $42.91 $42.91 Teira Austin $9.02 $9.02 $0.00 $0.00 Tiffany Buford $12.67 $12.67 $11.60 $11.60 Tiffany Pirtle $31.51 $31.51 $33.25 $33.25 Tijuana Johnson $0.00 $0.00 $2.15 $2.15 Tonya Larry $2.27 $2.27 $66.71 $66.71 Tyeshia Brown $4.67 $4.67 $0.00 $0.00 Tyra Cox $0.17 $0.17 $2.26 $2.26 Vydelia Parker $32.64 $32.64 $71.20 $71.20 Shatawan Dotts $1,000.00 Page 4 of 15 William Autry $33.89 $33.89 $20.91 $20.91 Willie Ray Bounds $0.57 $0.57 $1.23 $1.23 IT IS FURTHER ORDERED that on or before February 15, 2019, Defendants shall make all payments to Plaintiffs according to the following table: Name Current Claim W2 Current Claim 1099 Other Claims W2 Other Claims 1099 Alex Jones $47.60 $47.60 $156.45 $156.45 Amie Golimowski $0.98 $0.98 $7.97 $7.97 Andrew Hardin $2.87 $2.87 $0.00 $0.00 Aquice Collins $8.89 $8.89 $15.18 $15.18 Argo McMorris $47.72 $47.72 $70.59 $70.59 Ashley Jarrell $11.41 $11.41 $29.22 $29.22 Betty Clemons $9.24 $9.24 $19.63 $19.63 Betty Wilks $0.96 $0.96 $24.55 $24.55 Carla Jelks $0.89 $0.89 $1.52 $1.52 Catherine O'Connor Charmaine Davenport $0.00 $0.00 $2.66 $2.66 $11.92 $11.92 $0.00 $0.00 Constance Price $0.00 $0.00 $29.90 $29.90 Crystal Chatman $9.11 $9.11 $0.00 $0.00 Danny Waites $0.00 $0.00 $1.29 $1.29 Darnell Townsell $1.46 $1.46 $13.08 $13.08 Darnisha Walton $0.00 $0.00 $7.75 $7.75 Denise Brown $74.87 $74.87 $88.98 $88.98 Devon Burns $0.89 $0.89 $0.00 $0.00 Erica Dixon $0.00 $0.00 $5.17 $5.17 Evette Clark $0.00 $0.00 $23.91 $23.91 Janae Smith $7.06 $7.06 $10.62 $10.62 Jaquita Green $3.56 $3.56 $7.09 $7.09 Kaneshia Jones $1.52 $1.52 $12.28 $12.28 Karrimetha Walker $2.56 $2.56 $20.67 $20.67 Kathy Townsend $0.25 $0.25 $1.33 $1.33 Kenisha Davis $1.68 $1.68 $10.34 $10.34 Keondra Sanford $2.22 $2.22 $13.28 $13.28 Kiera Thompson $0.00 $0.00 $2.58 $2.58 Page 5 of 15 Kimberly Wright $0.00 $0.00 $1.40 $1.40 Lakesha Barefield $3.29 $3.29 $7.91 $7.91 Lannika Connor $0.00 $0.00 $1.04 $1.04 Laquita Allen $0.24 $0.24 $20.67 $20.67 Latasha Eskridge $0.25 $0.25 $5.46 $5.46 Latonya Parker $11.91 $11.91 $33.22 $33.22 Latrina Kittler $0.50 $0.50 $5.48 $5.48 Lawanda Carter $1.15 $1.15 $10.62 $10.62 Lucille Brawner $16.14 $16.14 $15.51 $15.51 Mi'Laija Hyche $3.78 $3.78 $18.61 $18.61 Monica Lambert $0.52 $0.52 $2.82 $2.82 Monique Grimes $18.24 $18.24 $23.59 $23.59 Natchia Harris $3.69 $3.69 $9.30 $9.30 Octavia Mitchell $0.25 $0.25 $2.73 $2.73 Pinkie Broadway $1.82 $1.82 $11.20 $11.20 Precious Benjamin $52.87 $52.87 $41.91 $41.91 Raven Bishop $18.36 $18.36 $17.76 $17.76 Roshelia Bush $0.00 $0.00 $7.97 $7.97 Schlonda Holifield $0.89 $0.89 $4.10 $4.10 Serenity Armstead $0.00 $0.00 $1.43 $1.43 Shakia Adams $0.24 $0.24 $2.58 $2.58 Shamika Christian $13.34 $13.34 $19.38 $19.38 Shannon Davis $0.24 $0.24 $3.88 $3.88 Sharon Washington $7.94 $7.94 $45.76 $45.76 Shatawan Dotts $22.21 $22.21 $24.55 $24.55 Shauntize Richards $6.71 $6.71 $7.75 $7.75 Star Davis-Stinson $14.30 $14.30 $0.00 $0.00 Tahesha Young Takiesha LambMalone $5.15 $5.15 $23.50 $23.50 $0.89 $0.89 $1.52 $1.52 Talisha Peete $0.69 $0.69 $7.96 $7.96 Taquita Hodges $2.67 $2.67 $6.46 $6.46 Tarrell Hogle $15.01 $15.01 $7.32 $7.32 Tasha Evans $1.07 $1.07 $2.79 $2.79 Tashiana Fleming $6.55 $6.55 $15.51 $15.51 Tatanashana Carter $23.24 $23.24 $53.12 $53.12 Teira Austin $14.04 $14.04 $0.00 $0.00 Tiffany Buford $19.70 $19.70 $14.36 $14.36 Tiffany Pirtle $49.01 $49.01 $41.17 $41.17 Tijuana Johnson $0.00 $0.00 $2.66 $2.66 Page 6 of 15 Tonya Larry $3.53 $3.53 $82.59 $82.59 Tyeshia Brown $7.27 $7.27 $0.00 $0.00 Tyra Cox $0.26 $0.26 $2.80 $2.80 Vydelia Parker $50.77 $50.77 $88.16 $88.16 William Autry $52.72 $52.72 $25.89 $25.89 Willie Ray Bounds $0.89 $0.89 $1.52 $1.52 IT IS FURTHER ORDERED that on or before August 15, 2019, Defendants shall make all payments to Plaintiffs according to the following table: Name Current Claim W2 Current Claim 1099 Other Claims W2 Other Claims 1099 Alex Jones $47.60 $47.60 $156.45 $156.45 Amie Golimowski $0.98 $0.98 $7.97 $7.97 Andrew Hardin $2.87 $2.87 $0.00 $0.00 Aquice Collins $8.89 $8.89 $15.18 $15.18 Argo McMorris $47.72 $47.72 $70.59 $70.59 Ashley Jarrell $11.41 $11.41 $29.22 $29.22 Betty Clemons $9.24 $9.24 $19.63 $19.63 Betty Wilks $0.96 $0.96 $24.55 $24.55 Carla Jelks $0.89 $0.89 $1.52 $1.52 Catherine O'Connor Charmaine Davenport $0.00 $0.00 $2.66 $2.66 $11.92 $11.92 $0.00 $0.00 Constance Price $0.00 $0.00 $29.90 $29.90 Crystal Chatman $9.11 $9.11 $0.00 $0.00 Danny Waites $0.00 $0.00 $1.29 $1.29 Darnell Townsell $1.46 $1.46 $13.08 $13.08 Darnisha Walton $0.00 $0.00 $7.75 $7.75 Denise Brown $74.87 $74.87 $88.98 $88.98 Devon Burns $0.89 $0.89 $0.00 $0.00 Erica Dixon $0.00 $0.00 $5.17 $5.17 Evette Clark $0.00 $0.00 $23.91 $23.91 Janae Smith $7.06 $7.06 $10.62 $10.62 Jaquita Green $3.56 $3.56 $7.09 $7.09 Kaneshia Jones $1.52 $1.52 $12.28 $12.28 Karrimetha Walker $2.56 $2.56 $20.67 $20.67 Page 7 of 15 Kathy Townsend $0.25 $0.25 $1.33 $1.33 Kenisha Davis $1.68 $1.68 $10.34 $10.34 Keondra Sanford $2.22 $2.22 $13.28 $13.28 Kiera Thompson $0.00 $0.00 $2.58 $2.58 Kimberly Wright $0.00 $0.00 $1.40 $1.40 Lakesha Barefield $3.29 $3.29 $7.91 $7.91 Lannika Connor $0.00 $0.00 $1.04 $1.04 Laquita Allen $0.24 $0.24 $20.67 $20.67 Latasha Eskridge $0.25 $0.25 $5.46 $5.46 Latonya Parker $11.91 $11.91 $33.22 $33.22 Latrina Kittler $0.50 $0.50 $5.48 $5.48 Lawanda Carter $1.15 $1.15 $10.62 $10.62 Lucille Brawner $16.14 $16.14 $15.51 $15.51 Mi'Laija Hyche $3.78 $3.78 $18.61 $18.61 Monica Lambert $0.52 $0.52 $2.82 $2.82 Monique Grimes $18.24 $18.24 $23.59 $23.59 Natchia Harris $3.69 $3.69 $9.30 $9.30 Octavia Mitchell $0.25 $0.25 $2.73 $2.73 Pinkie Broadway $1.82 $1.82 $11.20 $11.20 Precious Benjamin $52.87 $52.87 $41.91 $41.91 Raven Bishop $18.36 $18.36 $17.76 $17.76 Roshelia Bush $0.00 $0.00 $7.97 $7.97 Schlonda Holifield $0.89 $0.89 $4.10 $4.10 Serenity Armstead $0.00 $0.00 $1.43 $1.43 Shakia Adams $0.24 $0.24 $2.58 $2.58 Shamika Christian $13.34 $13.34 $19.38 $19.38 Shannon Davis $0.24 $0.24 $3.88 $3.88 Sharon Washington $7.94 $7.94 $45.76 $45.76 Shatawan Dotts $22.21 $22.21 $24.55 $24.55 Shauntize Richards $6.71 $6.71 $7.75 $7.75 Star Davis-Stinson $14.30 $14.30 $0.00 $0.00 Tahesha Young Takiesha LambMalone $5.15 $5.15 $23.50 $23.50 $0.89 $0.89 $1.52 $1.52 Talisha Peete $0.69 $0.69 $7.96 $7.96 Taquita Hodges $2.67 $2.67 $6.46 $6.46 Tarrell Hogle $15.01 $15.01 $7.32 $7.32 Tasha Evans $1.07 $1.07 $2.79 $2.79 Tashiana Fleming $6.55 $6.55 $15.51 $15.51 Tatanashana Carter $23.24 $23.24 $53.12 $53.12 Page 8 of 15 Teira Austin $14.04 $14.04 $0.00 $0.00 Tiffany Buford $19.70 $19.70 $14.36 $14.36 Tiffany Pirtle $49.01 $49.01 $41.17 $41.17 Tijuana Johnson $0.00 $0.00 $2.66 $2.66 Tonya Larry $3.53 $3.53 $82.59 $82.59 Tyeshia Brown $7.27 $7.27 $0.00 $0.00 Tyra Cox $0.26 $0.26 $2.80 $2.80 Vydelia Parker $50.77 $50.77 $88.16 $88.16 William Autry $52.72 $52.72 $25.89 $25.89 Willie Ray Bounds $0.89 $0.89 $1.52 $1.52 IT IS FURTHER ORDERED that on or before February 15, 2020, Defendants shall make all payments to Plaintiffs according to the following table: Name Current Claim W2 Current Claim 1099 Other Claims W2 Other Claims 1099 Alex Jones $47.60 $47.60 $156.45 $156.45 Amie Golimowski $0.98 $0.98 $7.97 $7.97 Andrew Hardin $2.87 $2.87 $0.00 $0.00 Aquice Collins $8.89 $8.89 $15.18 $15.18 Argo McMorris $47.72 $47.72 $70.59 $70.59 Ashley Jarrell $11.41 $11.41 $29.22 $29.22 Betty Clemons $9.24 $9.24 $19.63 $19.63 Betty Wilks $0.96 $0.96 $24.55 $24.55 Carla Jelks $0.89 $0.89 $1.52 $1.52 Catherine O'Connor Charmaine Davenport $0.00 $0.00 $2.66 $2.66 $11.92 $11.92 $0.00 $0.00 Constance Price $0.00 $0.00 $29.90 $29.90 Crystal Chatman $9.11 $9.11 $0.00 $0.00 Danny Waites $0.00 $0.00 $1.29 $1.29 Darnell Townsell $1.46 $1.46 $13.08 $13.08 Darnisha Walton $0.00 $0.00 $7.75 $7.75 Denise Brown $74.87 $74.87 $88.98 $88.98 Devon Burns $0.89 $0.89 $0.00 $0.00 Erica Dixon $0.00 $0.00 $5.17 $5.17 Evette Clark $0.00 $0.00 $23.91 $23.91 Page 9 of 15 Janae Smith $7.06 $7.06 $10.62 $10.62 Jaquita Green $3.56 $3.56 $7.09 $7.09 Kaneshia Jones $1.52 $1.52 $12.28 $12.28 Karrimetha Walker $2.56 $2.56 $20.67 $20.67 Kathy Townsend $0.25 $0.25 $1.33 $1.33 Kenisha Davis $1.68 $1.68 $10.34 $10.34 Keondra Sanford $2.22 $2.22 $13.28 $13.28 Kiera Thompson $0.00 $0.00 $2.58 $2.58 Kimberly Wright $0.00 $0.00 $1.40 $1.40 Lakesha Barefield $3.29 $3.29 $7.91 $7.91 Lannika Connor $0.00 $0.00 $1.04 $1.04 Laquita Allen $0.24 $0.24 $20.67 $20.67 Latasha Eskridge $0.25 $0.25 $5.46 $5.46 Latonya Parker $11.91 $11.91 $33.22 $33.22 Latrina Kittler $0.50 $0.50 $5.48 $5.48 Lawanda Carter $1.15 $1.15 $10.62 $10.62 Lucille Brawner $16.14 $16.14 $15.51 $15.51 Mi'Laija Hyche $3.78 $3.78 $18.61 $18.61 Monica Lambert $0.52 $0.52 $2.82 $2.82 Monique Grimes $18.24 $18.24 $23.59 $23.59 Natchia Harris $3.69 $3.69 $9.30 $9.30 Octavia Mitchell $0.25 $0.25 $2.73 $2.73 Pinkie Broadway $1.82 $1.82 $11.20 $11.20 Precious Benjamin $52.87 $52.87 $41.91 $41.91 Raven Bishop $18.36 $18.36 $17.76 $17.76 Roshelia Bush $0.00 $0.00 $7.97 $7.97 Schlonda Holifield $0.89 $0.89 $4.10 $4.10 Serenity Armstead $0.00 $0.00 $1.43 $1.43 Shakia Adams $0.24 $0.24 $2.58 $2.58 Shamika Christian $13.34 $13.34 $19.38 $19.38 Shannon Davis $0.24 $0.24 $3.88 $3.88 Sharon Washington $7.94 $7.94 $45.76 $45.76 Shatawan Dotts $22.21 $22.21 $24.55 $24.55 Shauntize Richards $6.71 $6.71 $7.75 $7.75 Star Davis-Stinson $14.30 $14.30 $0.00 $0.00 Tahesha Young Takiesha LambMalone $5.15 $5.15 $23.50 $23.50 $0.89 $0.89 $1.52 $1.52 Talisha Peete $0.69 $0.69 $7.96 $7.96 Taquita Hodges $2.67 $2.67 $6.46 $6.46 Page 10 of 15 Tarrell Hogle $15.01 $15.01 $7.32 $7.32 Tasha Evans $1.07 $1.07 $2.79 $2.79 Tashiana Fleming $6.55 $6.55 $15.51 $15.51 Tatanashana Carter $23.24 $23.24 $53.12 $53.12 Teira Austin $14.04 $14.04 $0.00 $0.00 Tiffany Buford $19.70 $19.70 $14.36 $14.36 Tiffany Pirtle $49.01 $49.01 $41.17 $41.17 Tijuana Johnson $0.00 $0.00 $2.66 $2.66 Tonya Larry $3.53 $3.53 $82.59 $82.59 Tyeshia Brown $7.27 $7.27 $0.00 $0.00 Tyra Cox $0.26 $0.26 $2.80 $2.80 Vydelia Parker $50.77 $50.77 $88.16 $88.16 William Autry $52.72 $52.72 $25.89 $25.89 Willie Ray Bounds $0.89 $0.89 $1.52 $1.52 IT IS FURTHER ORDERED that on or before August 15, 2020, Defendants shall make all payments to Plaintiffs according to the following table: Name Current Claim W2 Current Claim 1099 Other Claims W2 Other Claims 1099 Alex Jones $47.60 $47.60 $156.45 $156.45 Amie Golimowski $0.98 $0.98 $7.97 $7.97 Andrew Hardin $2.87 $2.87 $0.00 $0.00 Aquice Collins $8.89 $8.89 $15.18 $15.18 Argo McMorris $47.72 $47.72 $70.59 $70.59 Ashley Jarrell $11.41 $11.41 $29.22 $29.22 Betty Clemons $9.24 $9.24 $19.63 $19.63 Betty Wilks $0.96 $0.96 $24.55 $24.55 Carla Jelks $0.89 $0.89 $1.52 $1.52 Catherine O'Connor Charmaine Davenport $0.00 $0.00 $2.66 $2.66 $11.92 $11.92 $0.00 $0.00 Constance Price $0.00 $0.00 $29.90 $29.90 Crystal Chatman $9.11 $9.11 $0.00 $0.00 Danny Waites $0.00 $0.00 $1.29 $1.29 Darnell Townsell $1.46 $1.46 $13.08 $13.08 Darnisha Walton $0.00 $0.00 $7.75 $7.75 Page 11 of 15 Denise Brown $74.87 $74.87 $88.98 $88.98 Devon Burns $0.89 $0.89 $0.00 $0.00 Erica Dixon $0.00 $0.00 $5.17 $5.17 Evette Clark $0.00 $0.00 $23.91 $23.91 Janae Smith $7.06 $7.06 $10.62 $10.62 Jaquita Green $3.56 $3.56 $7.09 $7.09 Kaneshia Jones $1.52 $1.52 $12.28 $12.28 Karrimetha Walker $2.56 $2.56 $20.67 $20.67 Kathy Townsend $0.25 $0.25 $1.33 $1.33 Kenisha Davis $1.68 $1.68 $10.34 $10.34 Keondra Sanford $2.22 $2.22 $13.28 $13.28 Kiera Thompson $0.00 $0.00 $2.58 $2.58 Kimberly Wright $0.00 $0.00 $1.40 $1.40 Lakesha Barefield $3.29 $3.29 $7.91 $7.91 Lannika Connor $0.00 $0.00 $1.04 $1.04 Laquita Allen $0.24 $0.24 $20.67 $20.67 Latasha Eskridge $0.25 $0.25 $5.46 $5.46 Latonya Parker $11.91 $11.91 $33.22 $33.22 Latrina Kittler $0.50 $0.50 $5.48 $5.48 Lawanda Carter $1.15 $1.15 $10.62 $10.62 Lucille Brawner $16.14 $16.14 $15.51 $15.51 Mi'Laija Hyche $3.78 $3.78 $18.61 $18.61 Monica Lambert $0.52 $0.52 $2.82 $2.82 Monique Grimes $18.24 $18.24 $23.59 $23.59 Natchia Harris $3.69 $3.69 $9.30 $9.30 Octavia Mitchell $0.25 $0.25 $2.73 $2.73 Pinkie Broadway $1.82 $1.82 $11.20 $11.20 Precious Benjamin $52.87 $52.87 $41.91 $41.91 Raven Bishop $18.36 $18.36 $17.76 $17.76 Roshelia Bush $0.00 $0.00 $7.97 $7.97 Schlonda Holifield $0.89 $0.89 $4.10 $4.10 Serenity Armstead $0.00 $0.00 $1.43 $1.43 Shakia Adams $0.24 $0.24 $2.58 $2.58 Shamika Christian $13.34 $13.34 $19.38 $19.38 Shannon Davis $0.24 $0.24 $3.88 $3.88 Sharon Washington $7.94 $7.94 $45.76 $45.76 Shatawan Dotts $22.21 $22.21 $24.55 $24.55 Shauntize Richards $6.71 $6.71 $7.75 $7.75 Star Davis-Stinson $14.30 $14.30 $0.00 $0.00 Page 12 of 15 Tahesha Young Takiesha LambMalone $5.15 $5.15 $23.50 $23.50 $0.89 $0.89 $1.52 $1.52 Talisha Peete $0.69 $0.69 $7.96 $7.96 Taquita Hodges $2.67 $2.67 $6.46 $6.46 Tarrell Hogle $15.01 $15.01 $7.32 $7.32 Tasha Evans $1.07 $1.07 $2.79 $2.79 Tashiana Fleming $6.55 $6.55 $15.51 $15.51 Tatanashana Carter $23.24 $23.24 $53.12 $53.12 Teira Austin $14.04 $14.04 $0.00 $0.00 Tiffany Buford $19.70 $19.70 $14.36 $14.36 Tiffany Pirtle $49.01 $49.01 $41.17 $41.17 Tijuana Johnson $0.00 $0.00 $2.66 $2.66 Tonya Larry $3.53 $3.53 $82.59 $82.59 Tyeshia Brown $7.27 $7.27 $0.00 $0.00 Tyra Cox $0.26 $0.26 $2.80 $2.80 Vydelia Parker $50.77 $50.77 $88.16 $88.16 William Autry $52.72 $52.72 $25.89 $25.89 Willie Ray Bounds $0.89 $0.89 $1.52 $1.52 IT IS FURTHER ORDERED that Defendants shall make all payments, without any withholdings and to be reported on an IRS 1099 form, to Plaintiffs’ counsel, Hawks Quindel, S.C., according to the following schedule: DATE On or before August 15, 2018 On or before February 15, 2019 On or before August 15, 2019 On or before February 15, 2020 On or before August 15, 2020 AMOUNT $8,000.00 $8,000.00 $8,000.00 $8,000.00 $8,000.00 IT IS FURTHER ORDERED that Defendants shall deliver all payments described the paragraphs above by the respective dates set forth therein to Plaintiffs’ counsel at Hawks Quindel, S.C., Attn: Attorney Page 13 of 15 Timothy P. Maynard, 222 E. Erie Street, Suite 210, P.O. Box 442, Milwaukee, WI 53201-0442; IT IS FURTHER ORDERED that should Defendants fail to make the payments as set forth in the paragraphs above, Defendants shall have a period of five (5) business days to cure such breach by delivering payments to Plaintiffs’ counsel. Failure to timely cure such breach shall be deemed failure to comply with the mandatory injunction contained herein; IT IS FURTHER ORDERED that for any payment issued under the paragraphs above that becomes null and void as a result of not being cashed within ninety (90) days of issuance, Defendants shall reissue payment for such amounts to the parties’ elected cy pres recipient: The Employee Rights Advocacy Institute for Law & Policy, 2201 Broadway, Suite 310, Oakland, CA 94612. Defendants shall reissue such checks within sixty (60) days after the uncashed settlement checks become null and avoid and shall provide an accounting of all cy pres payments, including a copy of each check written to the cy pres recipient, to Plaintiffs’ counsel within fourteen (14) days of any cy pres payment; IT IS FURTHER ORDERED that by consent of the parties, the Court shall retain jurisdiction for the purpose of enforcing the terms of the settlement agreement and the mandatory injunction contained herein; and IT IS FURTHER ORDERED except as provided for in the paragraphs above, this case be and the same is hereby DISMISSED with prejudice and without further costs to either party. Page 14 of 15 Dated at Milwaukee, Wisconsin, this 14th day of May, 2018. BY THE COURT: J.P. Stadtmueller U.S. District Judge Page 15 of 15

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