Doria/Memon Discount Stores Wage and Hour Litigation

NOTICE OF SETTLEMENT OF CLASS ACTION AND FAIR LABOR STANDARDS ACT COLLECTIVE ACTION LAWSUIT

Current and former employees of the Discount Stores operated by Mohamed Doria and/or Iqbal Memon between October 4, 2008 and October 10, 2017 (the “Class Period”) whose names are included on the Absent Class Member List.

The Notice relates to a proposed settlement of wage and hour claims of current and former Discount Store workers at Defendants’ locations at any time between October 4, 2008 and October 10, 2017. The notice has been authorized by the United States District Court for the Southern District of New York. It contains important information about your right to receive a settlement check, to object to the settlement, or to elect not to be included in the settlement by excluding yourself from the case (“opt-out”).

Defendants have agreed to settle the employee wage and hour claims for work performed at the Discount Stores during the Class Period. The total settlement amount is $11,000,000. The Court has not decided who is right and who is wrong in this lawsuit. Your legal rights may be affected, and you have a choice to make now. These rights and options are summarized below and are fully explained in the Notice.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
PARTICIPATE:	Unless you exclude yourself from the settlement, you will be deemed to have participated in the class and will release your New York wage and hour claims. In addition, you can submit a Proof of Claim form to receive a payment. If you submit a Proof of Claim form, you also will release your minimum wage and overtime claims under the Fair Labor Standards Act. As described more fully below, if you wish to receive money as part of this settlement, you must submit a Claim Form and properly completed W-4 and W-9 Forms. If you need additional time to obtain a tax identification number you should send in the Claim Form without the tax identification information, seek to obtain a tax identification number and inform the Settlement Administrator of you efforts to obtain the tax identification number. If the Court approves this settlement, you should receive a settlement check within thirty days after the Court approves the Settlement and the Settlement has been funded by Defendants. There is currently a restriction in place in the Surrogate’s Court of Queens County limiting the Estate of Mohamed Doria from contributing to the Settlement. Full payment of the settlement funds can only be distributed once the restriction is lifted and the estate’s assets are liquidated.
EXCLUDE YOURSELF:	If you wish to exclude yourself (“opt-out”) from the lawsuit, you must follow the directions outlined in the Notice. If you opt out, you will not be part of the settlement but you will keep the right to bring your own case against Defendants with your own lawyers at your own expense.
OBJECT:	You can object by telling the Court what you do not like about the settlement and why it should not be approved. If you wish to object to the settlement, you must write to us at the address listed in the Notice, about why you believe the settlement is unreasonable, and must do so no later than September 21, 2020. If the Court rejects your objection, you will still be bound by the terms of the settlement.

In order to receive money from the settlement you must submit a claim and the required tax forms. If you do nothing, you will not receive any money from the settlement, but your New York State law claims will be released.