The proposed notice is materially defective and must not be transmitted in its current form. Because no notice has been sent, emailed, or mailed, no renewed decision period is required; the administrator should correct the notice first and then transmit the corrected version.

## Material Errors

| Item | Proposed Notice | Correct Amount | Error |
|---|---|---|---|
| Net class fund | $3,770,000 | $3,500,000 | Overstated by $270,000 |
| Value per point | Approximately $377 | $350.00 | Overstated by $27 per point |
| Maya Ortiz estimated payment | $2,262 | $2,100.00 | Overstated by $162 |

The $3,770,000 figure omitted the $270,000 payment to the Workplace Standards Agency.

Correct calculation:  
$5,400,000 − $1,350,000 − $110,000 − $140,000 − $30,000 − $270,000 = $3,500,000

Correct point value:  
$3,500,000 ÷ 10,000 = $350.00

Correct Maya Ortiz payment:  
6 × $350.00 = $2,100.00

The release paragraph is also materially overbroad. It describes a release of “all claims, known or unknown, arising from your employment through the date the court finally approves the settlement.” The executed release is limited to wage-statement and off-clock-work claims based on the complaint’s factual allegations, accruing from January 1, 2022 through June 30, 2025, and it excludes several categories.

## Corrected Paragraphs

**Replace the “Settlement amount and deductions” paragraph with:**

> **Settlement amount and deductions.** Defendant will pay $5,400,000 into the settlement fund. The proposed deductions and payments are: $1,350,000 for attorney fees; up to $110,000 for litigation costs; $140,000 for administration expenses; $30,000 total for three service awards; and $270,000 to the Workplace Standards Agency. These amounts are proposed and must be approved by the court. Using the maximum litigation costs, the estimated net class fund is $3,500,000.

**Replace the “How your payment is calculated” paragraph with:**

> **How your payment is calculated.** The administrator identified 10,000 total allocation points across 6,200 class members. The net class fund is divided by 10,000, so one point is currently estimated to be worth $350.00. Maya Ortiz has six points, so her estimated payment is 6 × $350.00 = $2,100.00, before required withholding. Estimates may change if the court approves different amounts or records are corrected.

**Replace the “Release” paragraph with:**

> **Release.** Unless you exclude yourself, you will release Defendant and the related persons identified in the settlement agreement only from wage-statement and off-clock-work claims—claims that Defendant provided inaccurate wage statements or failed to pay for off-clock work—based on the factual allegations in the complaint and accruing between January 1, 2022, and June 30, 2025. The release does not cover discrimination, harassment, retaliation, workers’ compensation, or vested-benefit claims, even if they arise from that period, and it does not cover claims arising after June 30, 2025.

## Provisions That Do Not Require Correction

The **Taxes** paragraph is accurate as written: it describes tax treatment as an estimate and states that it is not tax advice.

The **Your choices** paragraph is also accurate as to the deadlines and hearing date. The exclusion deadline and objection deadline are October 2, and the fairness hearing is November 13. The listed submission addresses should remain unchanged.

## Distribution Status

The administrator must stop the planned transmission, correct the notice using the language above, and then transmit. Because no notice has yet been distributed, no corrective notice and no renewed exclusion/objection period is required.