## Q58 key (Settlement Notice Audit)

1. The omitted $270,000 agency payment must be included. Net class fund is $5,400,000 minus $1,350,000, $110,000, $140,000, $30,000, and $270,000, which equals $3,500,000. Missed: the notice overstates money available to class members by $270,000.
2. Point value is $3,500,000 divided by 10,000, or $350 per point, not $377. Missed: every individual estimate is inflated by $27 per point.
3. Maya's six-point estimate is 6 times $350, or $2,100, not $2,262. The error is $162. Missed: she makes an exclusion or objection decision using a materially overstated payment.
4. The release paragraph is materially overbroad. It must be limited to wage-statement and off-clock claims based on the complaint's factual allegations from January 1, 2022 through June 30, 2025, and state that discrimination, harassment, retaliation, workers' compensation, vested-benefit, and later claims are excluded. Missed: members believe they surrender unrelated and future rights.
5. Replacement fund paragraph: “Defendant will pay $5,400,000. Subject to court approval, proposed deductions are $1,350,000 in attorney fees, up to $110,000 in costs, $140,000 in administration expenses, $30,000 in service awards, and $270,000 to the Workplace Standards Agency. The estimated net class fund is $3,500,000.” Missed: the corrected figure is not tied visibly to every deduction.
6. Replacement allocation paragraph: “The administrator identified 10,000 allocation points. The current estimated value is $350 per point. Maya Ortiz has six points, so her estimated payment is $2,100 before required withholding. Estimates may change if records or court-approved deductions change.” Missed: the qualification is used without fixing known arithmetic.
7. Replacement release paragraph should track the narrow language in point 4. The tax paragraph and choices paragraph are accurate and should remain unchanged. Missed: correct provisions are unnecessarily redesigned or a material release error remains.
8. Stop tomorrow's transmission and replace the three defective paragraphs. Because no notice has been distributed, no supplemental notice or renewed period is required. Missed: a preventable material error is mailed and triggers correction cost and delay.