Amanda Frlekin, et al. v. Apple Inc.

Case No. 13-cv-03451-WHA

United States District Court for the Northern District of California

NOTICE OF PENDENCY OF CLASS ACTION SETTLEMENT

A settlement agreement (the “Settlement”) has been reached between Apple and Plaintiffs Amanda Frlekin, Aaron Gregoroff, Seth Dowling, Debra Speicher, and Taylor Kalin (“Plaintiffs”) in a class action pending in the United States District Court for the Northern District of California (the “Court”). Plaintiffs Aaron Gregoroff, Seth Dowling, Debra Speicher, and Taylor Kalin (“Class Representatives”) are pursuing the Action on behalf of themselves and individuals who worked as a non-exempt employee at an Apple retail store in California at any time between July 25, 2009 and December 26, 2015 (“Settlement Class Members”). The “Class Period” is July 25, 2009 to December 31, 2015. Plaintiffs Amanda Frlekin and Taylor Kalin are also pursuing the Action on behalf of themselves, the State of California, and all individuals who worked as a non-exempt employee at an Apple retail store in California at any time from July 25, 2012 to December 26, 2015 (the “PAGA Settlement Class Members”) seeking civil penalties pursuant to the Private Attorneys’ General Act of 2004, California Labor Code section 2698 et seq. (“PAGA”).

The Court has preliminarily approved the Settlement. The Court appointed McLaughlin & Stern LLP and Kralowec Law P.C. to serve as Class Counsel for the Settlement Class Members, and Lee Shalov of McLaughlin & Stern LLP to serve as Lead Counsel for the Settlement Class Members. In making this appointment and preliminarily approving the Settlement, the Court gave these Class Counsel firms the authority to represent and bind the Plaintiffs and Settlement Class Members regarding the Settlement, subject to the Court’s final approval of the Settlement.

Important Dates

April 26, 2022 — Response Deadline For New Class Members To Submit Exclusion

April 26, 2022 — Response Deadline For All Class Members To File Objections To The Proposed Settlement

July 5, 2022 — Deadline To File An Objection To Final Approval Of The Settlement and Class Counsel’s Requests For Attorneys’ Fees and Costs

July 7, 2022, at 8:00 a.m. — Final Approval Hearing