You may be eligible to receive money from an employee class action lawsuit (“Action”) entitled Harris, et al. v. Watermark Services IV, LLC for alleged wage and hour violations. The Action was filed by former employees Telecia B. Harris and Dillan Burghart (together, “Plaintiffs”) against Watermark Services IV, LLC (“Defendant” or “Company”) and seek payment of (1) back wages and other relief for a class of all persons employed by Defendant in California and classified as an hourly, non-exempt employee who worked for Defendant during the Class Period (“Class” or “Class Members”), and (2) penalties under the California Private Attorney General Act (“PAGA”) for all persons employed by Defendant in California and classified as an hourly, non-exempt employee who worked for Defendant during the PAGA Period (“Aggrieved Employees”). The “Class Period” is the period June 1, 2022, to March 31, 2025, and the “PAGA Period” is the period June 6, 2022, to March 31, 2025.
The proposed Settlement has two main parts: (1) a Class Settlement requiring Company to fund Individual Class Payments, and (2) a PAGA Settlement requiring Company to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency (“LWDA”).
The Court has already preliminarily approved the proposed Settlement and approved the Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not act. Read the Notice carefully. You will be deemed to have carefully read and understood it. At the Final Approval Hearing, the Court will decide whether to finally approve the Settlement and how much of the Settlement will be paid to Plaintiffs and Plaintiffs’ attorneys (“Class Counsel”). The Court will also decide whether to enter a judgment that requires the Company to make payments under the Settlement and requires Class Members and Aggrieved Employees to give up their rights to assert certain claims against the Company.
If you worked for the Company during the Class Period and/or the PAGA Period, you have two options under the Settlement:
Do Nothing. You don’t have to do anything to participate in the proposed Settlement and be eligible for an Individual Class Payment and/or an Individual PAGA Payment. As a Participating Class Member, though, you will give up your right to assert Class Period wage claims and PAGA Period penalty claims against the Company.
Opt-Out of the Class Settlement. You can exclude yourself from the Class Settlement (opt-out) by submitting the written Request for Exclusion or otherwise notifying the Administrator in writing. If you opt-out of the Class Settlement, you will not receive an Individual Class Payment. You will, however, preserve your right to personally pursue Class Period wage claims against the Company, and, if you are an Aggrieved Employee, remain eligible for an Individual PAGA Payment. You cannot opt-out of the PAGA portion of the proposed Settlement.
The Company will not retaliate against you for any actions you take with respect to the proposed Settlement.
Your Legal Rights and Options | |
You Don’t Have to Do Anything to Participate in the Settlement | If you do nothing, you will be a Participating Class Member, eligible for an Individual Class Payment and an Individual PAGA Payment (if any). In exchange, you will give up your right to assert the wage claims against the Company that are covered by this Settlement (Released Class Claims). |
You Can Opt-out of the Class Settlement but not the PAGA Settlement | If you don’t want to fully participate in the proposed Settlement, you can opt-out of the Class Settlement by sending the Administrator a written Request for Exclusion. Once excluded, you will be a Non-Participating Class Member and no longer eligible for an Individual Class Payment. Non-Participating Class Members cannot object to any portion of the proposed Settlement. See Question 6. You cannot opt-out of the PAGA portion of the proposed Settlement. The Company must pay Individual PAGA Payments to all Aggrieved Employees. |
Participating Class Members Can Object to the Class Settlement but not the PAGA Settlement | All Class Members who do not opt-out (“Participating Class Members”) can object to any aspect of the proposed Class Settlement. The Court’s decision whether to finally approve the Settlement will include a determination of how much will be paid to Class Counsel and Plaintiffs who pursued the Action on behalf of the Class. You are not personally responsible for any payments to Class Counsel or Plaintiffs, but every dollar paid to Class Counsel and Plaintiffs reduces the overall amount paid to Participating Class Members. You can object to the amounts requested by Class Counsel or Plaintiffs if you think they are unreasonable. See Question 7. |
You Can Participate in the July 14, 2026 Final Approval Hearing | The Court’s Final Approval Hearing is scheduled to take place on July 14, 2026. You don’t have to attend but you do have the right to appear (or hire an attorney to appear on your behalf at your own cost), in person, by telephone or by using the Court’s virtual appearance platform. Participating Class Members can verbally object to the Class Settlement at the Final Approval Hearing. See Question 8. |
You Can Challenge the Calculation of Your Workweeks/Pay Periods | The amount of your Individual Class Payment and PAGA Payment (if any) depend on how many workweeks you worked at least one day during the Class Period (“Workweeks”) and how many pay periods you worked at least one day during the PAGA Period (“PAGA Pay Periods”), respectively. The number Workweeks and PAGA Pay Periods you worked according to the Company’s records is stated on the first page of the Notice. If you disagree with either of these numbers, you must challenge it by May 8, 2026. See Question 4. |
Upcoming Important Dates
Opt Out Deadline
5/8/2026
Objection Deadline
5/8/2026
Dispute Deadline
5/8/2026
Final Approval Hearing
7/14/2026