IN THE UNITED STATES DISTRICT COURT FOR ... - Cleveland.com

MELANIE WARREN 

and 

CAROL LASKOSKI, 

On behalf of themselves and all 

others similarly-situated, 

v. 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

Plaintiffs, 

MARK RACE, JOHN BULGARELLA, 

DALE FULLER, B. CHARLES AMES, 

HARVEY SANDERS AND NORBERT 

LEWANDOWSKI, 

Defendants. 

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CASE NO. 1:09-CV-2670 

JUDGE SOLOMON OLIVER, JR. 

MAG. JUDGE KENNETH S. McHARGH 

AGREEMENT OF SETTLEMENT AND 

RELEASE OF CLAIMS 

Subject to approval by the Court, this “AGREEMENT OF SETTLEMENT AND 

RELEASE OF CLAIMS” (“AGREEMENT”) is made and entered into by MELANIE WARREN 

and CAROL LASKOSKI (“Named Plaintiffs”), on behalf of themselves and all Existing Opt-In 

Plaintiffs, as defined below, and on behalf of all Other Eligible Settlement Participants as defined 

below who sign Consent and Release forms as provided herein, on the one hand, and MARK 

RACE, JOHN BULGARELLA, DALE FULLER, B. CHARLES AMES, HARVEY SANDERS 

and NORBERT LEWANDOWSKI (“Defendants”), on the other hand. Plaintiffs’ Counsel are 

Jason R. Bristol and Thomas A. Downie of Cohen, Rosenthal & Kramer LLP and Anthony J. 

Lazzaro of The Lazzaro Law Firm, LLC (collectively “Plaintiffs’ Counsel”). 

WHEREAS, the Named Plaintiffs have filed a lawsuit against Defendants alleging 

violations under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 216(b), for allegedly (1)

not paying the Named Plaintiffs and other similarly-situated salaried and hourly employees for 

all hours worked on behalf of InkStop, Inc. (“InkStop” or “the Company”) in violation of FLSA, 

29 U.S.C. §§ 201-219, and various state laws; and (2) misclassifying InkStop’s Store Managers, 

including Plaintiff Melanie Warren and other similarly-situated employees, as “exempt” 

employees, thus not paying them overtime compensation at the rate of one and one-half times 

their regular rate of pay for the hours they worked over 40 in a workweek in violation of the 

FLSA, 29 U.S.C. §§ 201-219 (“the Lawsuit”); and 

WHEREAS, Named Plaintiffs also filed a lawsuit against the Company and affiliated 

persons which, through their filing of their “First Amended Collective Action Complaint,” is 

now pending solely against Dirk Kettlewell and Dawn Callahan-Kettlewell, who are alleged to 

be “owners, directors and officers of InkStop, Inc.” titled Melanie Warren and Carol Laskoski 

vs. Dirk Kettlewell and Dawn Callahan-Kettlewell, Case No. 1:09-CV-2285 in the U.S. District 

Court for the Northern District of Ohio, Eastern Division, Judge Solomon Oliver, Jr. presiding 

(the “Related Lawsuit”). The Named Plaintiffs allege violations of the FLSA and various state 

laws for alleged non-payment of wages and misclassification of Store Managers — claims 

substantially similar to those in the Lawsuit; and 

WHEREAS, in addition to the Named Plaintiffs, 237 individuals have filed Consent 

Forms opting into the Lawsuit to date; 

WHEREAS, the individual members of the Board of Directors of InkStop — 

B. CHARLES AMES, RICHARD AMES, JOHN BULGARELLA, MICHAEL CLEGG, 

NORMAN ESIASON, DALE FULLER, WILLIAM HEINZERLING, JAMES HUMMER, 

DAWN CALLAHAN-KETTLEWELL, DIRK S. KETTLEWELL, NORBERT 

LEWANDOWSKI, JAMES MASTRIAN, MARK RACE, HARVEY SANDERS and 

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MICHAEL SHAUGHNESSY (“Directors”) — having learned of the alleged non-payment of 

wages to InkStop’s employees after September 13, 2009, have desired — well before the 

Lawsuit and the Related Lawsuit were filed — to compensate substantially these employees for 

their unpaid service to the Company, despite their belief that they have no legal obligation to do 

so; 

WHEREAS, as of the date of this Agreement, the Named Plaintiffs have incurred 

attorneys’ fees and incurred costs in the investigation and prosecution of the Lawsuit and the 

Related Lawsuit; 

WHEREAS, the Parties and Directors recognize that numerous bona fide disputes would 

need to be addressed were the Lawsuit and Related Lawsuit to continue including, without 

limitation, disputes concerning the liability of individuals under the FLSA in the circumstances 

existing here, the propriety of proceeding in the absence of InkStop which is in bankruptcy, 

numerous factual issues impacting the exempt status of the Store Managers and the good faith 

nature of Defendants’ actions, and that the resolution of the issues by the Court would have a 

substantial impact on the outcome of the Lawsuit and Related Lawsuit; 

WHEREAS, the Parties and the Directors desire to settle fully and finally all differences 

between them relating to InkStop’s compensation of Named Plaintiffs and all similarly-situated 

individuals, including, but not necessarily limited to, any differences embodied in or related to 

the Lawsuit and the Related Lawsuit; 

WHEREAS, the Parties and the Directors, with the assistance of the Wage & Hour office 

of the Department of Labor in Cleveland, Ohio, have identified the salaried and hourly 

employees employed by InkStop after September 13, 2009 who were allegedly not paid for 

some or all of their work after that date (except for the five InkStop officers who were members 

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of the Board of Directors) and who will be offered settlement payments in accordance with the 

terms of this Agreement and have compiled a list of all persons employed by InkStop as Store 

Managers after January 7, 2008; 

WHEREAS, Plaintiffs’ Counsel have conducted a thorough investigation into the facts of 

this Action, including reviewing relevant documents and researching the applicable law and the 

potential defenses, and based on their own independent investigation and evaluation, believe this 

settlement is fair, adequate and reasonable and in the best interest of the Plaintiffs in light of all 

known facts and circumstances, including the risk of significant delay, Defendants’ defenses and 

potential appellate issues, and Defendants’ counsel agree that this settlement is fair, adequate and 

reasonable; and; 

WHEREAS, this Agreement is not an admission by any of the Defendants in the Lawsuit 

and/or the Related Lawsuit, or of any of the Directors, of any wrongdoing or failure by InkStop 

or any other entity or person of failure to pay properly any InkStop employee as required by law. 

NOW, THEREFORE, in consideration of the promises and mutual promises herein 

contained, and other good and valuable consideration, the receipt and sufficiency of which is 

hereby acknowledged, the Parties and the Directors agree as follows: 

1. Definitions 

A. “Parties” shall mean Named Plaintiffs and Defendants. 

B. The “Existing Opt-In Plaintiffs” shall mean the persons listed on the List 

of Existing Opt-In Plaintiffs attached as Exhibit 1, and consisting of all individuals who 

submitted signed Consent Forms opting into this Lawsuit or the Related Lawsuit prior to the date 

of this Agreement. 

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C. The term “Other Eligible Settlement Participants” shall mean the persons 

listed in the List of Other Eligible Settlement Participants attached as Exhibit 2, and consisting of 

all persons (other than the Named Plaintiffs and Existing Opt-In Plaintiffs) who were (a) 

employed by InkStop after September 13, 2009 who were allegedly not paid for some or all of 

their work after that date (except officers of InkStop who were Directors and who will not 

participate), and (b) persons who worked for InkStop as Store Managers after January 7, 2008 

and who are listed on the List of InkStop Store Managers (Exhibit 3). 

D. The term “Individual Payment” shall mean a settlement payment 

calculated in accordance with the terms and conditions of this Agreement, after deductions 

approved by the Court for Service Awards to the Named Plaintiffs in recognition of their service 

as representative plaintiffs and attorneys’ fees and expense reimbursements to Plaintiffs’ 

Counsel, but before deduction of applicable tax withholdings in accordance with law. The 

Individual Payments to the Named Plaintiffs, the Existing Opt-In Plaintiffs, and the Other 

Eligible Settlement Participants, calculated in accordance with this Agreement, are stated in the 

Schedule of Individual Distributions (Exhibit 4). 

2. Settlement Process. 

A. Joint Motion for Court Approval. The Parties will jointly file a motion 

requesting entry by the Court of the proposed First Stipulated Order and Partial Final Judgment 

(Exhibit 5) (“First Stipulated Order”) approving, as fair and reasonable, the Settlement, this 

Settlement Agreement, and its Exhibits, including the proposed Notice of Settlement of InkStop 

Lawsuits (“Notice”) with attached Consent and Release form (“Consent and Release Form”) 

(Exhibit 6), the proposed allocation and calculation of settlement payments, the proposed Service 

Awards to the Named Plaintiffs, and the proposed attorneys’ fees and expense reimbursements to 

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Plaintiffs’ Counsel. As to the Named Plaintiffs and all Existing Opt-In Plaintiffs, the First 

Stipulated Order will ask the Court to grant final approval of the Settlement, dismiss their claims 

with prejudice, and enter final judgment dismissing them from the Lawsuit and the Related 

Lawsuit with prejudice, finding no just reason for delay. As to all Other Eligible Settlement 

Participants, the First Stipulated Order will ask the Court to grant preliminary approval of the 

settlement. 

B. Entry of First Stipulated Order. Entry by the Court of the proposed First 

Stipulated Order is a condition precedent to this Agreement and the implementation of the 

further steps of the settlement process described below. 

C. Notice to Existing Opt-In Plaintiffs and Other Eligible Settlement 

Participants. Within seven (7) days after the entry by the Court of the First Order, Plaintiffs’ 

Counsel will mail the Notice and attached Consent and Release Form to all Existing Opt-In 

Plaintiffs and all Other Eligible Settlement Participants. 

D. Early Deadline. The Early Deadline shall be the later of (1) twenty-one 

(21) days after the date of mailing of the Notice, or (2) the date signed Consent and Release 

Forms have been received from the Named Plaintiffs and at least ninety percent (90%) of the 

Existing Opt-In Plaintiffs or fifty percent (50%) of the Existing Opt-In Plaintiffs and Other 

Eligible Settlement Participants combined. 

E. Second Stipulated Order. Within seven (7) days after the Early Deadline 

or the date the First Stipulated Order has become non-appealable, whichever is later, the Parties 

will jointly file with the Court the proposed Second Stipulated Order and Partial Final Judgment 

(Exhibit 7) (“Second Stipulated Order”). The Parties will attach to the Second Stipulated Order 

(i) lists of all Named Plaintiffs, Existing Opt-In Plaintiffs, and Other Eligible Settlement 

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Participants who returned signed Consent and Release Forms on or before the Early Deadline, 

and (ii) copies of those individuals’ signed Consent and Release Forms (from which their 

addresses and social security numbers will be redacted). As to the Existing Opt-In Plaintiffs so 

listed, the Second Stipulated Order will ask the Court to approve the issuance of payment to 

them. As to the Other Eligible Settlement Participants so listed, the Second Stipulated Order will 

ask the Court to grant final approval of the Settlement as to such Other Eligible Settlement 

Participants, approve the issuance of payment to them, dismiss their claims with prejudice, and 

enter final judgment dismissing them from the Lawsuit and the Related Lawsuit with prejudice, 

finding no just reason for delay. 

F. Entry of Second Stipulated Order. Entry by the Court of the proposed 

Second Stipulated Order is a condition precedent to the implementation of the further steps of the 

settlement process described below. 

G. Early Settlement Distributions. Within ten (10) days after the entry by the 

Court of the Second Stipulated Order, the Settlement Administrator will issue (i) Individual 

Payments to the Named Plaintiffs, and to the Existing Opt-In Plaintiffs and Other Eligible 

Settlement Participants listed in the Second Stipulated Order, less deductions as provided below 

under Settlement Administration, (ii) Service Awards to the Named Plaintiffs of $2,500 each in 

recognition of their service as representative plaintiffs, less deductions as provided below under 

Settlement Administration, (iii) attorneys’ fees to Plaintiffs’ Counsel in an amount equal to 

16.66% of the Individual Payments issued to the Named Plaintiffs and to the Existing Opt-In 

Plaintiffs and Other Eligible Settlement Participants listed in the Second Stipulated Order, and 

(iv) expense reimbursements to Plaintiffs’ Counsel in the amount of $6,500. 

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H. Final Deadline. The Final Deadline shall be ninety (90) days after the date 

of mailing of the Notice, provided, however, the Directors shall have the option to extend the 

Final Deadline for an additional thirty (30) days. 

I. Third Stipulated Order. Within seven (7) days after the Final Deadline, 

the Parties will jointly file with the Court the proposed Third Stipulated Order and Final 

Judgment (Exhibit 8) (“Third Stipulated Order”). The Parties will attach to the Third Stipulated 

Order (i) lists of all Existing Opt-In Plaintiffs, and of all Other Eligible Settlement Participants, 

who returned signed Consent and Release Forms after the Early Deadline but on or before the 

Final Deadline, and (ii) copies of those individuals’ signed Consent and Release Forms (from 

which their addresses and social security numbers will be redacted). As to the Existing Opt-In 

Plaintiffs so listed, the Third Stipulated Order will ask the Court to approve the issuance of 

payment to them. As to the Other Eligible Settlement Participants so listed, the Third Stipulated 

Order will ask the Court to grant final approval of the Settlement as to such Other Eligible 

Settlement Participants, approve the issuance of Individual Payments to them, dismiss their 

claims with prejudice, and enter final judgment dismissing the Lawsuit and the Related Lawsuit 

with prejudice. 

J. Entry of the Third Stipulated Order. Entry by the Court of the proposed 

Third Stipulated Order is a condition precedent to the implementation of the further steps of the 

settlement process described below. 

K. Final Settlement Distributions. Within ten (10) days after the Third 

Stipulated Order has been entered, the Settlement Administrator will issue (i) Individual 

Payments to the Existing Opt-In Plaintiffs and Other Eligible Settlement Participants listed 

therein, less deduction as provided below under Settlement Administration, and (iii) attorneys’ 

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fees to Plaintiffs’ Counsel in an amount equal to the difference between the total of $110,000 and 

the attorneys’ fees issued to Plaintiffs’ Counsel pursuant to paragraph 2(G) above. 

3. Settlement Administration 

A. Guidelines for Settlement Administration. If the Court approves the 

Settlement as to the Named Plaintiffs and Existing Opt-In Plaintiffs and preliminarily approves 

the Settlement as to the Other Eligible Settlement Participants by entering the proposed First 

Stipulated Order, the Settlement will be administered by both Plaintiffs’ Counsel and Rust 

Consulting, Inc. or another third-party administrator selected by the Parties (“Settlement 

Administrator”). The costs of the Settlement Administrator, including the costs of establishing 

and administering the Qualified Settlement Fund, estimated to be $12,990.00, will be paid by the 

Directors. The following are general guidelines for administration: 

(1) Counsel for the Parties compiled the List of Other Eligible 

Settlement Participants based on a list of allegedly unpaid employees obtained 

from the Department of Labor and from the InkStop Bankruptcy Trustee, and the 

List of InkStop Store Managers. Counsel for the Parties compiled the list of 

InkStop Store Managers based on organizational charts and a payroll record for 

the last two years of operation obtained from InkStop’s former payroll servicing 

company. 

(2) Prior to the mailing of the Notice, lists of the Existing Opt-In 

Plaintiffs and Other Eligible Settlement Participants, both with last known 

addresses, will be provided to the Settlement Administrator who will make 

reasonable efforts to obtain valid current addresses for them through the National 

Change of Address Database. 

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(3) If an Other Eligible Settlement Participant contacts Plaintiffs’ 

Counsel, Plaintiffs’ Counsel shall encourage the Other Eligible Settlement 

Participant to participate in the Settlement and may discuss the terms of the 

Settlement with him or her. 

(4) If any former employee of InkStop who is not on the List of 

Existing Opt-In Plaintiffs or the List of Other Eligible Settlement Participants 

contacts the Settlement Administrator, Plaintiffs’ Counsel or Defendants’ Counsel 

prior to the Final Deadline and desires to participate in the settlement, 

Defendants’ counsel will consult with Plaintiffs’ Counsel, and then Defendants 

and Directors will decide, in their sole discretion, whether to allow the former 

employee to participate. If Defendants and Directors decide to allow such a 

former employee to participate, he or she will be given an opportunity to sign and 

return a Consent and Release Form, and upon doing so will be eligible to receive 

an Individual Payment calculated in accordance with this Agreement, which shall 

be paid by the Settlement Administrator from any remaining funds described in 

Paragraph 3(D) below or from funds provided by the Directors. 

B. Steps to Maximize Participation. The Parties and Directors agree that they 

share the objective of maximizing participation in the Settlement. In order to do so, the Parties 

agree that: 

(1) Thirty days after the date of the Notice, the Settlement 

Administrator will place automated phone calls to the Other Eligible Settlement 

Participants reminding them to sign and return the Consent and Release 

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(2) Sixty days after the date of the Notice, the Settlement 

Administrator will perform LEXIS-NEXIS credit header searches for all Existing 

Opt-In Plaintiffs and Other Eligible Settlement Participants who have not yet 

returned the Consent and Release, and 

(3) Sixty days after the date of the Notice, Plaintiffs’ Counsel will 

telephone and send a reminder letter to each Existing Opt-In Plaintiff and Other 

Eligible Settlement Participant who has not yet returned the Consent and Release. 

C. Qualified Settlement Fund and Deductions. The Settlement Administrator 

will establish a Qualified Settlement Fund and will distribute the settlement amounts to the 

Named Plaintiffs, the Existing Opt-In Plaintiffs, Other Eligible Settlement Participants, and 

Plaintiffs’ Counsel from the Qualified Settlement Fund as set forth in paragraphs 2 and 3 of this 

Agreement. From distributions to the Named Plaintiffs, the Existing Opt-In Plaintiffs, and Other 

Eligible Settlement Participants, the Settlement Administrator will deduct federal taxes, the 

employee’s share of FICA and Medicare, and applicable state and/or city taxes, and remit those 

payments to applicable authorities. The Settlement Administrator will also remit the employer’s 

share of FICA, Medicare, FUTA and state unemployment insurance which will be funded by the 

Directors. For distributions of attorneys’ fees and expense reimbursements, Plaintiffs’ Counsel 

will inform the Settlement Administrator of the amounts payable to each firm. 

D. Total Eligible Amount. The “Total Eligible Amount” of the Settlement 

shall be $660,000, and shall be deposited by the Directors with the Settlement Administrator as 

needed by the Settlement Administrator in order to timely make the distributions provided for in 

this Agreement. If the total distributions are less than $660,000, the undistributed balance will 

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emain the property of the Directors and will be returned to them within 30 days of the Final 

Settlement Distributions described in paragraph 2(K). 

E. Calculation of Individual Payments. Subject to approval by the Court, and 

in accordance with the terms and conditions of this Agreement including the Settlement Process 

described above, Named Plaintiffs, Existing Opt-In Plaintiffs, and Other Eligible Settlement 

Participants who have signed the Consent and Release Form will be eligible for Individual 

Payments calculated as follows. 

(1) After the deduction of Service Awards to the Named Plaintiffs and 

attorneys’ fees and expense reimbursements to Plaintiffs’ Counsel, the Total 

Eligible Amount shall be divided into Individual Payments as follows: 

(a) 90% of the Total Eligible Amount, after Court-approved 

deductions, shall be allocated to the payment of unpaid wages after 

September 13, 2009. The Individual Payments to the participants in this 

category are proportionate to their recoverable unpaid wages under the 

FLSA for work performed after September 13, 2009 as calculated by the 

U.S. Department of Labor, subject to a cap of $4,920.50. 

(b) 10% of the Total Eligible Amount, after Court-approved 

deductions, shall be allocated to persons who worked for InkStop as Store 

Managers after January 7, 2008. The Individual Payment in this category 

to Existing Opt-In Plaintiffs and Other Eligible Settlement Participants 

who are listed on the List of InkStop Store Managers shall be a per capita 

payment in the amount $169.34. 

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(c) Participants who fall within both groups are eligible for 

Individual Payments in each of the two categories. 

(d) The Individual Payments to the Named Plaintiffs, the 

Existing Opt-In Plaintiffs, and the Other Eligible Settlement Participants 

are stated in the Schedule of Individual Distributions (Exhibit 4). 

(2) Subject to approval by the Court, the total amount of the attorneys’ 

fees payable to Plaintiffs’ Counsel shall be 16.66% of the Total Eligible Amount, 

or $110,000, and Plaintiffs’ Counsel’s have incurred reimbursable litigation 

expenses of $6,500; 

(3) The sum of $2,500 shall be allocated as a “Service Award” to each 

Named Plaintiff in recognition of her service as a representative plaintiff for a 

total of $5,000. 

F. Payments Discharge Defendants’ Obligations. The payments described in 

this paragraph shall be in lieu of and discharge any and all obligations of InkStop, Defendants 

and Directors for lost compensation, of any kind and nature, to the Named Plaintiffs and the 

Existing Opt-In Plaintiffs, and to Other Eligible Settlement Participants who sign and return the 

Consent and Release Form. The payments described in this paragraph are also in full payment of 

attorneys’ fees and costs, including the cost of administering and obtaining the Consent and 

Releases. 

G. Tax Treatment of Payments. All payments to Named Plaintiffs, Existing 

Opt-In Plaintiffs, and Other Eligible Settlement Participants shall be reported as wages to the 

United States Internal Revenue Service and to other appropriate taxing authorities (“Taxing 

Authority” or “Taxing Authorities”) on a Form W-2 issued to each participant with that person’s 

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tax identification number, and shall be subject to deductions for applicable taxes and 

withholdings as required by federal, state and local law. Based on the request and 

representations of Plaintiffs’ Counsel, up to 16.66% of the Total Settlement Amount shall be 

considered attorneys’ fees (the exact amount to be determined pursuant to this Agreement) and 

reported on behalf of Plaintiffs’ Counsel to the Taxing Authorities on a Form 1099 issued to 

Plaintiffs’ Counsel with the tax identification number of Plaintiffs’ Counsel. In the event that it 

is subsequently determined by any Taxing Authority that any participant owes any additional 

taxes, interest, and/or penalties with respect to any money distributed under this Agreement, it is 

expressly agreed that the determination of any tax liability is between the participant and the 

Taxing Authority, and that Defendants and Directors will not be responsible for the payment of 

such taxes, including any interest and/or penalties thereon. 

H. Employer Payments. The Settlement Administrator will pay the employer 

share of FICA, Medicare, FUTA and state unemployment insurance, which will be funded by the 

Directors. 

4. Non-Admission of Liability. Defendants and Directors deny the allegations and 

claims asserted in the Lawsuit and the Related Lawsuit. The Parties understand and agree that 

this Agreement is a release of disputed claims and does not constitute an admission of liability on 

the part of Defendants and/or Directors. The Parties enter into this Agreement to avoid all 

further litigation and to compromise and resolve forever the matters that comprise both the 

Lawsuit and the Related Lawsuit, as well as all other matters released herein. 

5. Non-Admission of Class Liability. The Parties and Directors agree that this 

Agreement does not constitute, shall not be construed to be, and shall not be cited in or be 

admissible in any proceeding as evidence of: (a) a determination or admission that any group of 

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similarly situated employees exists to maintain a collective action under the FLSA or a class 

action under Rule 23 of the Federal Rules of Civil Procedure (or comparable state laws or rules), 

or (b) an adjudication of the merits of any factual or legal issue that was or could have been 

disputed by the Parties in the Lawsuit and/or the Related Lawsuit. Accordingly, the Parties and 

Directors agree that none of them has prevailed, nor shall this Agreement serve or be construed 

to be, nor cited in nor be admissible in any proceeding as, evidence that any of them has so 

prevailed. Notwithstanding the foregoing, the Parties and Directors agree that the Court’s entry 

of the Stipulated Order and Final Partial Judgment shall constitute a final judgment in the 

Lawsuit and Related Lawsuit with respect to the claims dismissed thereby, and the Stipulated 

Order and Final Judgment shall constitute a final judgment in the Lawsuit and Related Lawsuit 

with full res judicata effect. 

6. Release of Attorneys’ Fees and Costs for Settled Matters. Plaintiffs’ Counsel 

understand and agree that any fee payments made under this Agreement will be the full, final, 

and complete payment of all attorneys’ fees and costs arising from or relating to the 

representation of Named Plaintiffs, Existing Opt-In Plaintiffs, or Other Eligible Settlement 

Participants in the Lawsuit, the Related Lawsuit or otherwise. As an inducement to Defendants 

to enter into this Agreement, and as a material condition thereof, Plaintiffs’ Counsel hereby 

irrevocably and unconditionally release, acquit, and forever discharge, any claim they may have 

against InkStop, its officers, directors, management, representatives, employees and all other 

affiliated entities and/or persons (“Releasees”) for attorneys’ fees or costs arising from or related 

to the individuals and matters identified in this paragraph, and, as a further inducement to 

Defendants and Directors to enter into this Agreement, and as a material condition hereof, 

Plaintiffs’ Counsel further understand and agree that the fee and cost payments made pursuant to 

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paragraphs 2 and 3 of this Agreement will be the full, final and complete payment of all 

attorneys’ fees and costs that are released, acquitted, or discharged under this paragraph. 

7. Cooperation. The Parties and their respective counsel agree to cooperate fully 

with each other to obtain final approval of the settlement and effectuate its terms, including but 

not limited to execution of such documents and such other actions as may reasonably be 

necessary to implement the terms of this settlement. The Parties shall use their best efforts, 

including all efforts contemplated by this settlement and any other efforts that may become 

necessary by order of the Court, or otherwise, to effectuate the terms of this settlement. 

8. Authorization. The respective signatories to this Agreement represent that they 

are fully authorized to enter into this Agreement and bind the respective Parties to its terms and 

conditions. 

9. No Prior Assignments. The Parties and Plaintiffs’ Counsel represent, covenant 

and warrant that they have not directly or indirectly, assigned, transferred, encumbered or 

purported to assign, transfer or encumber to any person or entity any portion of any liability, 

claim, demand, action, cause of action or right released and discharged in this Agreement. 

10. Construction. The Parties agree that the terms and conditions of this Agreement 

are the result of lengthy, intensive arms-length negotiations between the Parties and that this 

Settlement Agreement shall not be construed in favor of or against any Party by reason of the 

extent to which any Party participated in the drafting of this Settlement Agreement. 

11. Modification. This Agreement may not be changed, altered or modified, except 

in writing and signed by the Parties, and approved by the Court. This Settlement Agreement 

may not be discharged except by performance in accordance with its terms or by a writing signed 

by the Parties. 

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12. Governing Law. This Agreement is made and entered into in the State of Ohio, 

and shall in all respects be interpreted, enforced, and governed by and under the laws of the State 

of Ohio. 

13. Binding Agreement. This Agreement shall be binding upon the Parties and the 

Existing Opt-In Plaintiffs, and upon Other Eligible Settlement Participants who sign and return 

Consent and Release Forms, and their respective heirs, trustees, executors, administrators, 

successors and assigns. 

14. Representation and Warranty of No Other Wage and Hour Claims. Named 

Plaintiffs represent and warrant that they do not have any other lawsuits, complaints or other 

claims pending against the Releasees except their Proofs of Claim in the InkStop Bankruptcy. 

Plaintiffs’ Counsel represent and warrant that they do not represent (a) any other current or 

former employees of InkStop, other than the Named Plaintiffs and the Existing Opt-In Plaintiffs 

in the Litigation, the Related Litigation, and the InkStop Bankruptcy, with respect to claims or 

potential claims under the Fair Labor Standards Act or any applicable state law seeking the 

payment of wages, overtime pay, bonuses, commissions, or other compensation that could have 

been brought in the Lawsuit and/or the Related Lawsuit, or a similar action in this or another 

jurisdiction. The Parties anticipate that Plaintiffs’ Counsel will represent Other Eligible 

Settlement Participants who sign and return Consent And Release Forms. Within seven (7) days 

after the entry by the Court of the Second Stipulated Order, Plaintiffs’ Counsel will file in the 

InkStop Bankruptcy proceeding a statement withdrawing the claims of the Named Plaintiffs and 

Existing Opt-In Plaintiffs, as well the claims of the Other Eligible Settlement Participants listed 

in the Second Stipulated Order. Within seven (7) days after the entry by the Court of the Third 

Stipulated Order, Plaintiffs’ Counsel will file in the InkStop Bankruptcy proceeding a statement 

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withdrawing the claims of the Other Eligible Settlement Participants listed in the Third 

Stipulated Order. 

15. Severability. Should any clause, sentence, provision, paragraph, or part of this 

Agreement be adjudged by any court of competent jurisdiction, or be held by any other 

competent governmental authority having jurisdiction, to be illegal, invalid, or unenforceable, 

such judgment or holding shall not affect, impair, or invalidate the remainder of this Agreement, 

but shall be confined in its operation to the clause, sentence, provision, paragraph, or part of the 

Agreement directly involved, and the remainder of the Agreement shall remain in full force and 

effect. 

16. No Waiver. The failure to enforce at any time, or for any period of time, any one 

or more of the terms of this Agreement shall not be a waiver of such terms or conditions or of 

such party’s right thereafter to enforce each and every term and condition of this Agreement. 

17. Sole and Entire Agreement. This Agreement sets forth the entire agreement 

between the Parties, and fully supersedes any and all prior oral or written agreements or 

understandings between the Parties pertaining to the subject matter hereof. This Agreement may 

only be modified in writing. 

18. Headings and Captions. The headings and captions used in this Agreement are 

for convenience or reference only, and shall in no way define, limit, expand or otherwise affect 

the meaning or the construction of any provision of this Agreement. 

19. Counterparts. This Agreement may be executed in two or more counterparts, 

each of which counterpart shall be deemed to be an original, and all such counterparts shall 

constitute one and the same instrument. 

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LIST OF EXISTING OPT-IN PLAINTIFFS 

NUMBER LAST NAME FIRST NAME 

1 AGNEW DANIEL 

2 ALEJOS MATTHEW 

3 AMIN MEHULKUMAR 

4 ANDERSON RONALD 

5 ARAGON ALFONSO 

6 AUEL CHRISTOPHER 

7 BAILEY CATHERINE 

8 BAKER ALEXANDRA 

9 BARTOS KIMBERLY 

10 BAUER VALERIE 

11 BELL LANA 

12 BELL JUSTIN 

13 BLAKE PATRICK 

14 BOOTH SCOTT 

15 BOWEN AUDREY 

16 BOWER GLEN 

17 BOYDA CHARLES 

18 BOYER TRAVIS 

19 BOYLE TIMOTHY 

20 BROWN CHARLES 

21 BULL JOHN 

22 BURROUGHS NATALIE 

23 BURTON JOHN 

24 BYRNES RYAN 

25 CAMPBELL STEPHEN 

26 CARESS STEPHANIE 

27 CASTOR HEATHER 

28 CAVANAUGH CHRISTINE 

29 CHASTINE MICHAEL 

30 CIARULA CRISTINA 

31 COHEN MICHAEL 

32 COHEN RODNEY 

33 COLTS ERIC 

34 COOK JAMES 

35 COOK AMBER 

36 COPLING BRIAN 

37 CORSUN LAURA 

38 CREASY LOXLEY 

39 CUNNINGHAM BRIAN 

40 DAVENPORT NICOLA 

41 DAY SHARON 

42 DICERBO CATHLEEN 

43 DILLON BRIAN 

44 DINNESEN JARED 

45 DOSS CHRISTIE 

46 DOWLER KEVIN 

47 DRAKE STEPHEN 

48 DURST SHIRLEY 

49 EISENTROUT STEVEN 

50 ELLIS MARK 

51 ELLIS JESSICA 

52 ESQUEDA ZAVIER 

53 FERRANTE DOMINICK 

54 FITZ MATHEW 

55 FOREMAN JAMES 

56 FOSTER RANELL 

57 GARZA NICOLE 

58 GERSTENBERGER BRUCE 

59 GIACOBBE VALERIE 

60 GIESLER JORDIN 

61 GILBERT ERIC 

62 GONGRE MICHAEL 

1 

Exhibit 1



63 GONZALES JUSTIN 

64 GONZALEZ EDGARDO 

65 GOOSTREE TIFFANY 

66 GRAY ROBERT 

67 GUERREIRO SERGIO 

68 HALEY RACHEL 

69 HAMER FRANCIS 

70 HAMMOND JENNIFER 

71 HARRINGTON THOMAS 

72 HEARD DARRYELLE 

73 HENLEY CHRISTINA 

74 HETTLER CHRISTOPHER 

75 HICKS JENNIFER 

76 HIGGINS RICHARD 

77 HILYARD TYLER 

78 HOBBS IV WILLIAM 

79 HOGG ABEY 

80 HOOD SUSAN 

81 HUMENIK NICHOLE 

82 HUNTT RYAN 

83 JACOBS SALLY 

84 JAKUBCZYK TOBIASZ 

85 JANOYAN SONIA 

86 JARVIS V CASPER 

87 JONES CHRISTOPHER 

88 JONES JR KENNETH 

89 KARISH JUSTIN 

90 KAUFFMAN BENJAMIN 

91 KELLEHER SEAN 

92 KILGORE CLAYTON 

93 KINNEY CHRISTOPHER 

94 KOEHLER KATHERINE 

95 KOPELOW MARK 

96 KOWALSKI AARON 

97 KRIESHER JAMES 

98 KRIVOSHEY ADAM 

99 KRIVOSHEY ALAN 

100 KUNA LYNN 

101 KURTZ SHARON 

102 LAGAMBINA MICHAEL 

103 LAMBAKIS MATTHEW 

104 LANDES BRIDGETT 

105 LARSEN JENNIFER 

106 LEAHY GABRIELLE 

107 LEE SCOT 

108 LEONOV IGOR 

109 LIGHT TIMOTHY 

110 LINN RICHARD 

111 LIPNICK SCOTT 

112 LOCKETT III CARL 

113 LOMBARDO CRYSTAL 

114 LOOMIS RAYMOND 

115 LOPEZ LEONARD 

116 LUBAS JOHN 

117 LUCAS AMANDA 

118 MANOS DANIEL 

119 MARINO STEFANO 

120 MARINO HEATHER 

121 MARLIN SHAWN 

122 MASTELLONE LINDA 

123 MASYUK STEPAN 

124 McARTHUR PAUL 

2



125 MCCALLISTER TERRY 

126 MCCALLISTER SHARON 

127 MCGEE PATRICK 

128 MCGOWAN CATHLYN 

129 MCGREW CIARA 

130 METOYER JENNIFER 

131 MICHELON LARRY 

132 MILICIA ROBERT 

133 MONROE PERRY 

134 MORGAN NEIL 

135 MORGAN DAYNE 

136 MORRIS TRAYVEOWNE 

137 MURACO LAURA 

138 NAGEL CHRISTINA 

139 NEEDHAM JR. LAWRENCE 

140 NICHOLS MATTHEW 

141 NICKLESS KIMBERLY 

142 OPYRCHAL JUSTIN 

143 OWEN ANGELA 

144 OWENS STEPHANIE 

145 OWENS ANDREW 

146 OWSIK EDWARD 

147 PACIMEO TRACY 

148 PARKER R JASON 

149 PARKER AMY 

150 PATRICK STEPHEN 

151 PEABODY KYLE 

152 PEARCE DAVID 

153 PEARSON SHEFTON 

154 PEDRAZA AMANDA 

155 PENA CRISTA 

156 PHELPS JEREMY 

157 PHILLIPS KAYLA 

158 PIERCE II JAMES 

159 PIZZINI DEBORAH 

160 PLANK GLENN 

161 PORTER KAREN 

162 PUGH DARNELL 

163 QUERASHI RAHMAN 

164 QUIRK KELLY 

165 RAINEY-CAMERON THELMA 

166 REESE CHENE 

167 RICHARDSON KELLIE 

168 RICHTER MICHELLE 

169 RONKY ROBERT 

170 ROSTA MICHELE 

171 ROTHACKER GREGORY 

172 ROULSTON ANTHONY 

173 RUSHING SUSAN 

174 SAVAGE DEREK 

175 SAVOY ASHTON 

176 SCHLACHTA ROBERT 

177 SCHMEHL CHRISTIAN 

178 SCOTT JUSTIN 

179 SCRUTON JAMES 

180 SESTITO JUSTIN 

181 SHARIN ALBERT 

182 SHULMAN DAWNMARIE 

183 SIMOES JAYSON 

184 SIMS JR JAMES 

185 SISTRUNK KATHRYN 

186 SMITH JUSTIN 

3



187 SMITH JULIE 

188 SMITH DALE 

189 SMYKSY MICHAEL 

190 SOVIAR II STEPHEN 

191 SPARKS ANDREW 

192 STEYSKAL REX 

193 STOTT ROBERT 

194 STRODE JR ARTHUR 

195 STUCKERT MICHAEL 

196 STUCKERT DAVIS HOLLY 

197 STULL GENEVIEVE 

198 TEAGUE STEVEN 

199 THOMAS JESSICA 

200 THOMPSON BOBBY 

201 THOMPSON JOHN 

202 THOMPSON II ROBERT 

203 TODD KENNETH 

204 TOVAR REGINA 

205 TRAVIS COREY 

206 TROCHE DARREN 

207 TUCCIARONE ANTHONY 

208 TYLER SHAWN 

209 UNTHANK NICHOLAS 

210 URBAN MORTON 

211 URBANO CAROLINE 

212 VANEVERY MATTHEW 

213 VARAGONA JAMES 

214 VASSALLO MARIA 

215 VENER COLLEEN 

216 VENTURA ANTHONY 

217 WADE JULIE 

218 WADE MARCUS 

219 WALKER MELANIE 

220 WALKER CHANDA 

221 WALTON JR GRADY 

222 WARD PHILIP 

223 WEEDEN DUJUANE 

224 WESP II DAVID 

225 WHITE JAY 

226 WILDT KRISTIN 

227 WILLIAMS KEVIN 

228 WILSON GERRY 

229 WILSON LISA 

230 WINDWILLOW CELINE 

231 WISNIEWSKI ALEXANDER 

232 WOLF BRIAN 

233 WOODALL AMANDA 

234 WRIGHT JERRY 

235 YGLECIAS STACY 

236 YOUNG MATTHEW 

237 ZICKWOLF KENNETH 

4

LIST OF OTHER ELIGIBLE SETTLEMENT PARTICIPANTS 


1 AARONS ZACHARY 

2 ABERNATHY DONALD 

3 AGOSTO EDGAR 

4 ALARCON ALAN 

5 ALBIN MARC 

6 ALBIN-BROOKS IAN 

7 ALEXANDER RENEE 

8 ALFORD BLAIR 

9 ALLEN ANTHONY 

10 ALVA JR ANDREW 

11 ANDERSON DINA 

12 ANDERSON RYAN 

13 ANDRIST NATHAN 

14 ARMSTRONG HEATHER 

15 ASHCRAFT ERIK 

16 BAKER DOROTHY 

17 BARTZ KARL 

18 BARYSCHPOLEC NATASHA 

19 BASTIAN ANDREA 

20 BATCSICS CHRISTOPHER 

21 BATENCOURT RAYNELLE 

22 BATES JESSICA 

23 BEARD CLAUDIA 

24 BEAUBIEN STEPHEN 

25 BECK SERGEI 

26 BECK ADAM 

27 BECKWITH DEREK 

28 BEGICH JOSEPH 

29 BELL CHARLISE 

30 BELVEDERE ESTEBAN 

31 BLANCHARD MICHAEL 

32 BLATTER GARY 

33 BOYD JAMES 

34 BRADFORD KYLA 

35 BREWER ARTHUR 

36 BREWER JOSHUA 

37 BRISCOE JR JOHN 

38 BROWN KELLY 

39 BROWN JENNIFER 

40 BROWN JR ANGELO 

41 BROWNE ERIN 

42 BRUCE SYLINDA 

43 BRUCKEN GILBERT 

44 BUSH JOSEPH 

45 BYRD KRAIG 

46 CAMDEN PAUL 

47 CARL EDWARD 

48 CARPENTER DANIEL 

49 CARR DAVID 

50 CARTER CELINA 

51 CATO DANIEL 

52 CHANDLER NICHOLAS 

53 CHAPPELL JUSTIN 

54 CHARNEY KELLY 

55 CHEN SEAN 

56 CHENEY MIYUKI 

57 CHOATE WILLIAM 

58 CHOATE JESSE 

59 CHOWDHURY RIFAT 

60 CHRISIAN TAMMY 

61 CHRISTENSEN MICHAEL 

62 CITTADINO DIANE 

1 

Exhibit 2



63 CLARK III LONNIE 

64 CLELAND BEN 

65 COLLINS KAREN 

66 CONNORS JAMES 

67 CONTI PATRICIA 

68 COOK AARON 

69 COOPER C L 

70 COOPER JAMES 

71 COOPER BRADLEY 

72 COOPER CHRISTOPHER 

73 CORREA JUAN 

74 COX KATHRYN 

75 CREWS MARC 

76 CROCKARELL MICHAEL 

77 CROW RAYMON 


79 CYWINSKI MELODY 

80 CZERW GARY 

81 DALLAIRE THEODORE 

82 DALTON KENNETH 

83 DAVIS TRACY 

84 DEAN KHALIL 

85 DEKACZ DAVID 

86 DELBRIDGE JASON 

87 DENCHFIELD SCOTT 

88 DICKERSON LISA 

89 DIEFENDERFER DEBORAH 

90 DIGIOLAMO JOSEPH 

91 DIMARIA ROSS 

92 DOUGHERTY PATRICK 

93 DOUGLAS ARMEIN 

94 DUER JAMES 

95 DUNFIELD CARL 

96 ECKROATE DENISE 

97 EDMONDSON TRACY 

98 EDMUNDS DANIEL 

99 EDMUNDS CHRIS 

100 EGBERT JOHN 

101 EPISCOPO VINCENT 

102 EZZO CHRISTINA 

103 FENNER MARK 

104 FINDLAY MARCEL 

105 FITZGERALD ANNETTE DAWN 

106 FLORES AVELINO 

107 FLOWERS LYNETTE 

108 FLURY BRANDON 

109 FORSCHINO MICHAEL 

110 FRANCIS KELLY 

111 FRISK DAVID 

112 FUENTEZ MICHAEL 

113 FUSSEL TONYA 

114 GAETAN ANGEL 

115 GAGNON EMILY 

116 GALAVIZ JULIAN 

117 GALINDO AARON 

118 GARDNER BENJAMIN 

119 GAVULIC RYAN 

120 GERBA CHARLES 

121 GERHARDT TRAVIS 

122 GOLDEN TIMOTHY 

123 GOMEZ ROMAN 

124 GONZALES ARI 

2



125 GORSKI GARY 

126 GRAZIATO ROBERT 

127 GREEN PAUL 

128 GULLICKSON ERIK 

129 GUZMAN LUZ 

130 HABECKER JASON 

131 HACKENBERRY PHILIP 

132 HAIRSTON AARON 

133 HALEY WYATT 

134 HALL DWAYNE 

135 HAMMAR BRIAN 

136 HAMMONDS STEPHANIE 

137 HANNAH MONICA 

138 HARRIS TONISHIA 

139 HARROD MELISSA 

140 HARTLEY KEVIN 

141 HARTWECK JR HAROLD 

142 HARVEY WHITNEY 

143 HASTINGS ANTHONY 

144 HAYNES CATHY 

145 HEDGEPETH RICHARD 

146 HENEHAN MICHAEL 

147 HERMAN JOSEPH 

148 HIGGANBOTHAM DEVIN 

149 HIGGINS MICHELLE 

150 HILL DOMINIQUE 

151 HILL DAVID 

152 HOARD LYNN 

153 HOGAN BRYAN 

154 HOLEN BENJAMIN 

155 HOOVER BARBARA 

156 HOWELL PATRICIA 

157 HSIEH LEAH 

158 HUBERT ANTHONY 

159 HUTSON CURTIS 

160 HYND LINDA 

161 JACKSON CHAD 

162 JACKSON ROBYN 

163 JACKSON GREGORY 

164 JANAS DAVID 

165 JANKS ALEXANDER 

166 JENKINS DIANE 

167 JEWELL CHRISTINA 

168 JOHNS CREIGHTON 

169 JOHNSON KEITH 

170 JOHNSON THOMAS 

171 JOHNSON KAREN 

172 JOHNSTON EVERETT 

173 JOINER ABOUELFAIOUD STEPHANIE 

174 JONES CONNIE 

175 JONES DWAYNE 

176 JORKASKY III RICHARD 

177 KARABINUS WILLIAM 

178 KEIFFER AMBER 

179 KEITH DUSTEN 

180 KELLEY MARYON 

181 KELLY JOSEPH 

182 KENTZ GREGORY 

183 KERN NIKOLE 

184 KETTLEWELL STEVEN 


186 KIROUAC MICHAEL 

3



187 KLOVSKI KATRINA 

188 KNISELY STEPHEN 

189 KORPASH ANDREW 

190 KRAATZ MATTHEW 

191 KUXHAUSEN AMANDA 

192 LAHOUD STEVEN 

193 LASKO JEFFREY 

194 LASPINA ROBERT 

195 LAUB BARRY 

196 LAYLIN JEFFREY 

197 LEACH JASON 

198 LESAK ANDREW 

199 LEWELLEN KENNETH 

200 LEWIS STACEY 

201 LEWIS CHRISTINA 

202 LEWISON MICHAEL 

203 LINK RICHARD 

204 LOHMAR DANNY 

205 LOPEZ REINALDO 

206 LUKANS BRETT 

207 LYNCH CHRISTOPHER 

208 LYNN GREG 

209 MARLER CORY 

210 MARSHALL WILLIAM 

211 MATTHEWS MATEA 

212 MAXWELL ALLYSON 

213 MAXWELL SEAN 

214 MCCLELLAND CHRISTOPHER 

215 MCGEE LISA 

216 MCGEE MICHELLE 

217 MCGRATH THEODORE 

218 MCGUIRE ROBERT 

219 MCKENZIE KENNITH 

220 MCLANE RACHEL 

221 MCMAHAN BRANDON 

222 MCMURRAY RANDY 

223 MEEUWEN ANDREW 

224 MELEWSKI PETER 

225 MENDOZA RICHARD 

226 MEYER JOHN 

227 MEYER ERIC 

228 MIDDLETON PATRICK 

229 MILES JOHN 

230 MILES JIM 

231 MILES MATHEW 

232 MILLER LAWRENCE 

233 MISTECKA MEGAN 

234 MITCHELL HOLLIE 

235 MOCZ MATTHEW 

236 MOHRMANN KEITH 

237 MONASTYRENKO EVGENI 

238 MONK MATTHEW 

239 MONROE PHILLIP 

240 MOORE LORI 

241 MOORE III ALVIN 

242 MORELL ZACHARY 

243 MORELL JAMES 

244 MOSEE JAMES 

245 MOTES RUSSELL 

246 MOYER JOANNE 

247 MULL KATRINA 

248 MURPHY JR DANIEL 

4



249 MURRAY VINCENT 

250 NAGEL RON 

251 NESBIT JR WAYNE 

252 NGUYEN HIEU 

253 NICHOLS TIFFANY 

254 NICHOLSON LEON 

255 NIGRELLI MATTHEW 

256 NITTO RICHARD 

257 NOLL DEREK 

258 NORMAN JONATHAN 

259 NORRIS TIMOTHY 

260 O DONNELL BRIAN 

261 O DONNELL MIKE 

262 OBEIDAT AMANDA 

263 OJAMETS RIINO 

264 OPALINSKI BRIAN 

265 OSMANI RAFFEY 

266 OSTERHOUDT FRANK 

267 PAHEL ALLEN 

268 PALISWAT BRAD 

269 PALLONE BENJAMIN 

270 PAMPUSH JUSTIN 

271 PANICO JOHN 

272 PATEL SAMIR 

273 PENNINGTON KEITH 

274 PERSSON SCOTT 

275 PETERS JON 

276 PETERS ROBERT 

277 PETERSEN BRIAN 

278 PETERSEN KIM 

279 PHILLIPS BRAIN 

280 PHILLIPS LORA 

281 PIENDZIK BRANDON 

282 PITTMAN JR GREGORY 

283 POLCAR PAUL 

284 POOLE JORDAN 

285 POOR SETH 

286 POPE RANCE 

287 PRATT KEVIN 

288 PRICE CHRISTOPHER 

289 PYE DAVID 

290 QUANDT KATHRYN 

291 QUIGLEY RALPH 

292 QUIRK SEAN 

293 RACZ MICHAEL 

294 REDFORD SONYA 

295 REED MARION 


297 REPICKY MARK 

298 REYNOLDS HEATHER 

299 RICHESIN CHARLIE 

300 RICHEY KEVIN 

301 RICKMAN JEFFERY 

302 RIGLER SHANNON 

303 ROBERTS CHARLES 

304 ROEDER ERIC 

305 ROGERS AMANDA 

306 ROGERS JOHNSON KAREN 

307 ROGOVITZ BRIAN 

308 ROGOVITZ ERIC 

309 ROMERO MANUEL 

310 ROSENBERG ALBERT 

5



311 ROUTMAN MITCHELL 

312 ROX MELODY 

313 RUFENER WENDY 

314 RUMSEY ROBERT 

315 RYDBOM CALVIN 

316 SABIO ANDREW 

317 SAFFER JASON 

318 SAIENNI VINCENT 

319 SALERNO STEVEN 

320 SAUNDERS DANA 

321 SCHLOSSER THERESA 

322 SCHMIDT DUANE 

323 SCHUHWERK ERIK 

324 SEACREST CHAD 

325 SEAGER DAVID 

326 SEARS LESLIE 

327 SEITZINGER GEORGE 

328 SEMAN CRAIG 

329 SHARPE JUSTIN 

330 SHAUGHNESSY ANNE 

331 SHAWKI MICHAEL 

332 SHEPHERD WILLIAM 

333 SHEPPARD ALFONSO 

334 SHOTTE DANIEL 

335 SHOWERS NANCY 

336 SIGNORELLI LOUIS 


338 SMITH DEANNA 

339 SMITH JARVIS 

340 SMITH JR ROBERT 

341 SNEIDERMAN MARC 

342 SNYDER JOANNE 

343 SOKOLOSKI ANTHONY 

344 SOLLARS DAVID 

345 SPICKENAGEL MARK 

346 STECKY MATTHEW 

347 STEIN JONATHAN 

348 STEKO DARIO 

349 STELLA RYAN 

350 STEPHENS BETH 

351 STEVENS CHRIS 

352 STEWART NATALIE 

353 STOGDILL TERRY 

354 STURDY SARA 

355 SURVOY GARY 

356 THOMAS GLENN 

357 TOBER CLAYTON 

358 TOKARCIK PATRICIA 

359 TUCKER JOHNATHAN 

360 TURNER JASON 

361 UNGER JOHN 

362 URMETZ PATRICIA 

363 USOCCHI MICHAEL 


365 VASSMER FALISHA 

366 VENTURA LYDIA 

367 VOGEL CASEY 

368 VROMAN JOSHUA 

369 WALLACE JAMAR 

370 WALTON DAVID 

371 WARNER LANIRA 

372 WATSON JAMES 

6



373 WECHSLER STEVEN 

374 WEEKS TIFFANY 

375 WELSH DAVID 

376 WESSON TYRUS 

377 WESTOVER LEONA 

378 WHITE TAMARIA 

379 WHITE WILLIAM 

380 WIENSZCZAK ERIC 

381 WILKEN DEBRA 

382 WILLIAMS MARC 

383 WILLIAMS TAYLOR PAULETTE 

384 WILSON GRADY 

385 WINSLOW WADE 

386 WOOD BRYAN 

387 WRIGHT AARON 

388 YOUNT DIANA 

389 YUROCKO DEBBIE 

390 ZETAH ERIC 

7

LIST OF INKSTOP STORE MANAGERS 


1 AARONS ZACHARY 

2 ABERNATHY DONALD 

3 AGOSTO EDGAR 

4 ALARCON ALAN 

5 ALBIN MARC 

6 ALBIN-BROOKS IAN 

7 ALEXANDER RENEE 

8 ALFORD BLAIR 

9 ALLEN ANTHONY 

10 ALVA JR ANDREW 

11 ANDERSON DINA 

12 ANDERSON RYAN 

13 ARMSTRONG HEATHER 

14 ASHCRAFT ERIK 

15 AUEL CHRISTOPHER 

16 BARTZ KARL 

17 BARYSCHPOLEC NATASHA 

18 BATENCOURT RAYNELLE 

19 BAUER VALERIE 

20 BEAUBIEN STEPHEN 

21 BECKWITH DEREK 

22 BELL LANA 

23 BLAKE PATRICK 

24 BOWER GLEN 

25 BOYD JAMES 

26 BOYDA CHARLES 

27 BOYER TRAVIS 

28 BRADFORD KYLA 

29 BREWER ARTHUR 

30 BRISCOE JR JOHN 

31 BROWN KELLY 

32 BROWN JENNIFER 

33 BULL JOHN 

34 BURTON JOHN 

35 BUSH JOSEPH 

36 BYRNES RYAN 

37 CAMDEN PAUL 

38 CAMPBELL STEPHEN 

39 CARL EDWARD 

40 CARR DAVID 

41 CASTOR HEATHER 

42 CHANDLER NICHOLAS 

43 CHARNEY KELLY 

44 CHASTINE MICHAEL 

45 CHOATE WILLIAM 

46 CHRISIAN TAMMY 

47 CHRISTENSEN MICHAEL 

48 CITTADINO DIANE 

49 CLELAND BEN 

50 COLTS ERIC 

51 CONNORS JAMES 

52 COOPER C L 

53 COOPER JAMES 

54 CREASY LOXLEY 

55 CREWS MARC 

56 CROCKARELL MICHAEL 

57 CROW RAYMON 


59 CZERW GARY 

60 DALLAIRE THEODORE 

61 DAVENPORT NICOLA 

62 DEAN KHALIL 

1 

Exhibit 3



63 DEKACZ DAVID 

64 DELBRIDGE JASON 

65 DENCHFIELD SCOTT 

66 DICERBO CATHLEEN 

67 DIEFENDERFER DEBORAH 

68 DIGIOLAMO JOSEPH 

69 DILLON BRIAN 

70 DIMARIA ROSS 

71 DOUGLAS ARMEIN 

72 DUER JAMES 

73 DUNFIELD CARL 

74 EDMONDSON TRACY 

75 EDMUNDS DANIEL 

76 EDMUNDS CHRIS 

77 EISENTROUT STEVEN 

78 ELLIS MARK 

79 EPISCOPO VINCENT 

80 EZZO CHRISTINA 

81 FENNER MARK 

82 FINDLAY MARCEL 

83 FITZ MATHEW 

84 FITZGERALD ANNETTE DAWN 

85 FOREMAN JAMES 

86 FORSCHINO MICHAEL 

87 FUENTEZ MICHAEL 

88 FUSSEL TONYA 

89 GAETAN ANGEL 

90 GALINDO AARON 

91 GAVULIC RYAN 

92 GERHARDT TRAVIS 

93 GOLDEN TIMOTHY 

94 GONGRE MICHAEL 

95 GONZALES ARI 

96 GONZALEZ EDGARDO 

97 GOOSTREE TIFFANY 

98 GORSKI GARY 

99 GRAZIATO ROBERT 

100 HACKENBERRY PHILIP 

101 HAIRSTON AARON 

102 HALEY WYATT 

103 HALL DWAYNE 

104 HAMMONDS STEPHANIE 

105 HANNAH MONICA 

106 HARROD MELISSA 

107 HARTLEY KEVIN 

108 HARTWECK JR HAROLD 

109 HASTINGS ANTHONY 

110 HAYNES CATHY 

111 HEDGEPETH RICHARD 

112 HENLEY CHRISTINA 

113 HETTLER CHRISTOPHER 

114 HIGGANBOTHAM DEVIN 

115 HIGGINS RICHARD 

116 HILL DOMINIQUE 

117 HILL DAVID 

118 HOARD LYNN 

119 HOGAN BRYAN 

120 HOLEN BENJAMIN 

121 HOOD SUSAN 

122 HOOVER BARBARA 

123 HOWELL PATRICIA 

124 HUBERT ANTHONY 

2



125 HUTSON CURTIS 

126 JACKSON CHAD 

127 JANOYAN SONIA 

128 JEWELL CHRISTINA 

129 JOHNS CREIGHTON 

130 JOHNSON KEITH 

131 JOHNSON THOMAS 

132 JOHNSON KAREN 

133 JONES CONNIE 

134 JONES DWAYNE 

135 JONES CHRISTOPHER 

136 JORKASKY III RICHARD 

137 KARABINUS WILLIAM 

138 KAUFFMAN BENJAMIN 

139 KEITH DUSTEN 

140 KELLEHER SEAN 

141 KENTZ GREGORY 

142 KERN NIKOLE 

143 KETTLEWELL STEVEN 


145 KINNEY CHRISTOPHER 

146 KIROUAC MICHAEL 

147 KLOVSKI KATRINA 

148 KOPELOW MARK 

149 KUXHAUSEN AMANDA 

150 LEWIS STACEY 

151 LEWISON MICHAEL 

152 LINK RICHARD 

153 LINN RICHARD 

154 LIPNICK SCOTT 

155 LOCKETT III CARL 

156 LOHMAR DANNY 

157 LOOMIS RAYMOND 

158 LOPEZ LEONARD 

159 LUBAS JOHN 

160 LUCAS AMANDA 

161 LUKANS BRETT 

162 LYNCH CHRISTOPHER 

163 LYNN GREG 

164 MARINO STEFANO 

165 MARINO HEATHER 

166 MARSHALL WILLIAM 

167 MATTHEWS MATEA 

168 McARTHUR PAUL 

169 MCCALLISTER TERRY 

170 MCCLELLAND CHRISTOPHER 

171 MCGEE LISA 

172 MCGEE PATRICK 

173 MCGEE MICHELLE 

174 MCGOWAN CATHLYN 

175 MCGRATH THEODORE 

176 MCGREW CIARA 

177 MCGUIRE ROBERT 

178 MCLANE RACHEL 

179 MCMAHAN BRANDON 

180 MCMURRAY RANDY 

181 MELEWSKI PETER 

182 MENDOZA RICHARD 

183 MEYER JOHN 

184 MIDDLETON PATRICK 

185 MILES JOHN 

186 MILES JIM 

3



187 MILLER LAWRENCE 

188 MISTECKA MEGAN 

189 MITCHELL HOLLIE 

190 MONROE PERRY 

191 MOORE LORI 

192 MOORE III ALVIN 

193 MOTES RUSSELL 

194 MOYER JOANNE 

195 MULL KATRINA 

196 MURPHY JR DANIEL 

197 MURRAY VINCENT 

198 NAGEL RON 

199 NAGEL CHRISTINA 

200 NEEDHAM JR. LAWRENCE 

201 NESBIT JR WAYNE 

202 NICHOLS TIFFANY 

203 NICHOLSON LEON 

204 NITTO RICHARD 

205 NORMAN JONATHAN 

206 O DONNELL BRIAN 

207 O DONNELL MIKE 

208 OJAMETS RIINO 

209 OPALINSKI BRIAN 

210 OPYRCHAL JUSTIN 

211 OSMANI RAFFEY 

212 OSTERHOUDT FRANK 

213 OWENS STEPHANIE 

214 OWSIK EDWARD 

215 PACIMEO TRACY 

216 PANICO JOHN 

217 PARKER R JASON 

218 PATEL SAMIR 

219 PEDRAZA AMANDA 

220 PENNINGTON KEITH 

221 PETERS JON 

222 PETERSEN BRIAN 

223 PHELPS JEREMY 

224 PHILLIPS BRAIN 

225 PHILLIPS KAYLA 

226 PIENDZIK BRANDON 

227 PIERCE II JAMES 

228 PIZZINI DEBORAH 

229 PLANK GLENN 

230 POLCAR PAUL 

231 POOR SETH 

232 POPE RANCE 

233 PRATT KEVIN 

234 PUGH DARNELL 

235 QUIGLEY RALPH 


237 REPICKY MARK 

238 RICHARDSON KELLIE 

239 RICHESIN CHARLIE 

240 RICHEY KEVIN 

241 RICHTER MICHELLE 

242 RICKMAN JEFFERY 

243 ROBERTS CHARLES 

244 ROEDER ERIC 

245 ROGERS JOHNSON KAREN 

246 ROGOVITZ BRIAN 

247 ROMERO MANUEL 

248 RONKY ROBERT 

4



249 ROSENBERG ALBERT 

250 ROSTA MICHELE 

251 ROTHACKER GREGORY 

252 ROULSTON ANTHONY 

253 ROX MELODY 

254 RUMSEY ROBERT 

255 RYDBOM CALVIN 

256 SABIO ANDREW 

257 SAFFER JASON 

258 SAIENNI VINCENT 

259 SAUNDERS DANA 

260 SCHMEHL CHRISTIAN 

261 SCHMIDT DUANE 

262 SCHUHWERK ERIK 

263 SCRUTON JAMES 

264 SEACREST CHAD 

265 SHARPE JUSTIN 

266 SHAWKI MICHAEL 

267 SHEPHERD WILLIAM 

268 SHEPPARD ALFONSO 

269 SHOTTE DANIEL 

270 SHULMAN DAWNMARIE 

271 SISTRUNK KATHRYN 


273 SOVIAR II STEPHEN 

274 SPICKENAGEL MARK 

275 STEKO DARIO 

276 STEVENS CHRIS 

277 STEWART NATALIE 

278 STOGDILL TERRY 

279 STOTT ROBERT 

280 SURVOY GARY 

281 THOMAS GLENN 

282 THOMAS JESSICA 

283 THOMPSON BOBBY 

284 TODD KENNETH 

285 TOVAR REGINA 

286 TUCCIARONE ANTHONY 

287 TUCKER JOHNATHAN 

288 TURNER JASON 

289 UNGER JOHN 

290 URBANO CAROLINE 

291 VANEVERY MATTHEW 

292 VARAGONA JAMES 


294 VENTURA LYDIA 

295 WADE JULIE 

296 WALKER MELANIE 

297 WALLACE JAMAR 

298 WALTON JR GRADY 

299 WARREN MELANIE 

300 WATSON JAMES 

301 WECHSLER STEVEN 

302 WELSH DAVID 

303 WESP II DAVID 

304 WESSON TYRUS 

305 WHITE TAMARIA 

306 WIENSZCZAK ERIC 

307 WILDT KRISTIN 

308 WILKEN DEBRA 

309 WILLIAMS MARC 

310 WILLIAMS TAYLOR PAULETTE 

5



311 WILSON GRADY 

312 WOLF BRIAN 

313 WRIGHT AARON 

314 WRIGHT JERRY 

315 YGLECIAS STACY 

316 YUROCKO DEBBIE 

317 ZETAH ERIC 

318 ZICKWOLF KENNETH 

6

SCHEDULE OF INDIVIDUAL PAYMENTS 

(After Service Awards, Attorneys' Fees, and Litigation Expenses) 

NON-PAYMENT STORE MANAGER TOTAL INDIV. 

LAST NAME FIRST NAME AMOUNTS AMOUNTS PAYMENTS 

AARONS ZACHARY $169.34 $169.34 

ABERNATHY DONALD $169.34 $169.34 

AGNEW DANIEL $536.23 $536.23 

AGOSTO EDGAR $1,625.54 $169.34 $1,794.88 

ALARCON ALAN $169.34 $169.34 

ALBIN MARC $1,407.43 $169.34 $1,576.77 

ALBIN-BROOKS IAN $1,506.02 $169.34 $1,675.36 

ALEJOS MATTHEW $658.02 $658.02 

ALEXANDER RENEE $169.34 $169.34 

ALFORD BLAIR $169.34 $169.34 

ALLEN ANTHONY $169.34 $169.34 

ALVA JR ANDREW $169.34 $169.34 

AMIN MEHULKUMAR $217.39 $217.39 

ANDERSON DINA $169.34 $169.34 

ANDERSON RYAN $1,550.21 $169.34 $1,719.55 

ANDERSON RONALD $507.24 $507.24 

ANDRIST NATHAN $493.93 $493.93 

ARAGON ALFONSO $657.96 $657.96 

ARMSTRONG HEATHER $1,407.43 $169.34 $1,576.77 

ASHCRAFT ERIK $169.34 $169.34 

AUEL CHRISTOPHER $1,506.27 $169.34 $1,675.61 

BAILEY CATHERINE $115.53 $115.53 

BAKER DOROTHY $505.41 $505.41 

BAKER ALEXANDRA $317.00 $317.00 

BARTOS KIMBERLY $634.30 $634.30 

BARTZ KARL $169.34 $169.34 

BARYSCHPOLEC NATASHA $169.34 $169.34 

BASTIAN ANDREA $322.68 $322.68 

BATCSICS CHRISTOPHER $132.39 $132.39 

BATENCOURT RAYNELLE $169.34 $169.34 

BATES JESSICA $671.69 $671.69 

BAUER VALERIE $1,550.21 $169.34 $1,719.55 

BEARD CLAUDIA $326.65 $326.65 

BEAUBIEN STEPHEN $1,427.82 $169.34 $1,597.16 

BECK SERGEI $249.51 $249.51 

BECK ADAM $493.40 $493.40 

BECKWITH DEREK $169.34 $169.34 

BEGICH JOSEPH $4,014.68 $4,014.68 

BELL LANA $636.79 $169.34 $806.13 

BELL CHARLISE $541.19 $541.19 

BELL JUSTIN $599.52 $599.52 

BELVEDERE ESTEBAN $595.67 $595.67 

BLAKE PATRICK $1,174.84 $169.34 $1,344.18 

BLANCHARD MICHAEL $2,635.98 $2,635.98 

BLATTER GARY $3,954.01 $3,954.01 

BOOTH SCOTT $592.42 $592.42 

BOWEN AUDREY $518.36 $518.36 

BOWER GLEN $1,427.82 $169.34 $1,597.16 

BOYD JAMES $169.34 $169.34 

BOYDA CHARLES $1,669.50 $169.34 $1,838.84 

BOYER TRAVIS $1,427.83 $169.34 $1,597.17 

BOYLE TIMOTHY $775.68 $775.68 

BRADFORD KYLA $169.34 $169.34 

BREWER ARTHUR $169.34 $169.34 

BREWER JOSHUA $498.25 $498.25 

BRISCOE JR JOHN $169.34 $169.34 

BROWN KELLY $169.34 $169.34 

BROWN CHARLES $869.73 $869.73 

BROWN JENNIFER $169.34 $169.34 

BROWN JR ANGELO $1,678.25 $1,678.25 

BROWNE ERIN $349.12 $349.12 

BRUCE SYLINDA $612.95 $612.95 

1 

Exhibit 4





BRUCKEN GILBERT $3,163.21 $3,163.21 

BULL JOHN $1,581.61 $169.34 $1,750.95 

BURROUGHS NATALIE $594.67 $594.67 

BURTON JOHN $1,393.31 $169.34 $1,562.65 

BUSH JOSEPH $1,931.04 $169.34 $2,100.38 

BYRD KRAIG $509.31 $509.31 

BYRNES RYAN $1,647.48 $169.34 $1,816.82 

CAMDEN PAUL $169.34 $169.34 

CAMPBELL STEPHEN $1,647.50 $169.34 $1,816.84 

CARESS STEPHANIE $644.30 $644.30 

CARL EDWARD $169.34 $169.34 

CARPENTER DANIEL $538.12 $538.12 

CARR DAVID $169.34 $169.34 

CARTER CELINA $615.79 $615.79 

CASTOR HEATHER $1,405.85 $169.34 $1,575.19 

CATO DANIEL $657.96 $657.96 

CAVANAUGH CHRISTINE $521.73 $521.73 

CHANDLER NICHOLAS $1,788.71 $169.34 $1,958.05 

CHAPPELL JUSTIN $486.18 $486.18 

CHARNEY KELLY $169.34 $169.34 

CHASTINE MICHAEL $1,493.75 $169.34 $1,663.09 

CHEN SEAN $599.58 $599.58 

CHENEY MIYUKI $606.62 $606.62 

CHOATE WILLIAM $1,346.24 $169.34 $1,515.58 

CHOATE JESSE $557.64 $557.64 

CHOWDHURY RIFAT $452.11 $452.11 

CHRISIAN TAMMY $169.34 $169.34 

CHRISTENSEN MICHAEL $1,550.22 $169.34 $1,719.56 

CIARULA CRISTINA $595.67 $595.67 

CITTADINO DIANE $169.34 $169.34 

CLARK III LONNIE $712.01 $712.01 

CLELAND BEN $169.34 $169.34 

COHEN MICHAEL $809.29 $809.29 

COHEN RODNEY $472.81 $472.81 

COLLINS KAREN $1,976.99 $1,976.99 

COLTS ERIC $1,506.27 $169.34 $1,675.61 

CONNORS JAMES $169.34 $169.34 

CONTI PATRICIA $4,014.68 $4,014.68 

COOK AARON $261.81 $261.81 

COOK JAMES $268.73 $268.73 

COOK AMBER $447.67 $447.67 

COOPER C L $571.72 $169.34 $741.06 

COOPER JAMES $1,606.68 $169.34 $1,776.02 

COOPER BRADLEY $231.76 $231.76 

COOPER CHRISTOPHER $1,669.46 $1,669.46 

COPLING BRIAN $511.62 $511.62 

CORREA JUAN $681.73 $681.73 

CORSUN LAURA $577.63 $577.63 

COX KATHRYN $815.66 $815.66 

CREASY LOXLEY $1,405.87 $169.34 $1,575.21 

CREWS MARC $169.34 $169.34 

CROCKARELL MICHAEL $169.34 $169.34 

CROW RAYMON $1,788.70 $169.34 $1,958.04 

CUNNINGHAM BRIAN $169.34 $169.34 

CUNNINGHAM BRIAN $1,493.71 $1,493.71 

CYWINSKI MELODY $640.34 $640.34 

CZERW GARY $169.34 $169.34 

DALLAIRE THEODORE $169.34 $169.34 

DALTON KENNETH $333.80 $333.80 

DAVENPORT NICOLA $1,596.71 $169.34 $1,766.05 

DAVIS TRACY $576.92 $576.92 

DAY SHARON $672.40 $672.40 

2





DEAN KHALIL $169.34 $169.34 

DEKACZ DAVID $169.34 $169.34 

DELBRIDGE JASON $169.34 $169.34 

DENCHFIELD SCOTT $169.34 $169.34 

DICERBO CATHLEEN $1,305.45 $169.34 $1,474.79 

DICKERSON LISA $3,295.01 $3,295.01 

DIEFENDERFER DEBORAH $169.34 $169.34 

DIGIOLAMO JOSEPH $169.34 $169.34 

DILLON BRIAN $1,405.85 $169.34 $1,575.19 

DIMARIA ROSS $169.34 $169.34 

DINNESEN JARED $803.06 $803.06 

DOSS CHRISTIE $428.27 $428.27 

DOUGHERTY PATRICK $587.39 $587.39 

DOUGLAS ARMEIN $169.34 $169.34 

DOWLER KEVIN $615.55 $615.55 

DRAKE STEPHEN $601.77 $601.77 

DUER JAMES $1,741.62 $169.34 $1,910.96 

DUNFIELD CARL $169.34 $169.34 

DURST SHIRLEY $586.21 $586.21 

ECKROATE DENISE $621.88 $621.88 

EDMONDSON TRACY $169.34 $169.34 

EDMUNDS DANIEL $169.34 $169.34 

EDMUNDS CHRIS $169.34 $169.34 

EGBERT JOHN $532.26 $532.26 

EISENTROUT STEVEN $1,493.75 $169.34 $1,663.09 

ELLIS MARK $589.76 $169.34 $759.10 

ELLIS JESSICA $622.29 $622.29 

EPISCOPO VINCENT $169.34 $169.34 

ESQUEDA ZAVIER $356.46 $356.46 

EZZO CHRISTINA $1,729.06 $169.34 $1,898.40 

FENNER MARK $169.34 $169.34 

FERRANTE DOMINICK $478.26 $478.26 

FINDLAY MARCEL $169.34 $169.34 

FITZ MATHEW $1,550.22 $169.34 $1,719.56 

FITZGERALD ANNETTE DAWN $169.34 $169.34 

FLORES AVELINO $235.25 $235.25 

FLOWERS LYNETTE $541.79 $541.79 

FLURY BRANDON $963.23 $963.23 

FOREMAN JAMES $1,713.41 $169.34 $1,882.75 

FORSCHINO MICHAEL $169.34 $169.34 

FOSTER RANELL $554.15 $554.15 

FRANCIS KELLY $425.73 $425.73 

FRISK DAVID $936.52 $936.52 

FUENTEZ MICHAEL $169.34 $169.34 

FUSSEL TONYA $169.34 $169.34 

GAETAN ANGEL $169.34 $169.34 

GAGNON EMILY $628.80 $628.80 

GALAVIZ JULIAN $313.10 $313.10 

GALINDO AARON $169.34 $169.34 

GARDNER BENJAMIN $237.21 $237.21 

GARZA NICOLE $419.22 $419.22 

GAVULIC RYAN $169.34 $169.34 

GERBA CHARLES $4,014.68 $4,014.68 

GERHARDT TRAVIS $169.34 $169.34 

GERSTENBERGER BRUCE $591.47 $591.47 

GIACOBBE VALERIE $2,636.05 $2,636.05 

GIESLER JORDIN $498.84 $498.84 

GILBERT ERIC $540.23 $540.23 

GOLDEN TIMOTHY $169.34 $169.34 

GOMEZ ROMAN $231.76 $231.76 

GONGRE MICHAEL $1,669.46 $169.34 $1,838.80 

GONZALES ARI $169.34 $169.34 

3





GONZALES JUSTIN $678.61 $678.61 

GONZALEZ EDGARDO $1,669.46 $169.34 $1,838.80 

GOOSTREE TIFFANY $1,537.65 $169.34 $1,706.99 

GORSKI GARY $169.34 $169.34 

GRAY ROBERT $2,855.68 $2,855.68 

GRAZIATO ROBERT $169.34 $169.34 

GREEN PAUL $625.19 $625.19 

GUERREIRO SERGIO $555.86 $555.86 

GULLICKSON ERIK $559.18 $559.18 

GUZMAN LUZ $525.40 $525.40 

HABECKER JASON $628.98 $628.98 

HACKENBERRY PHILIP $169.34 $169.34 

HAIRSTON AARON $169.34 $169.34 

HALEY WYATT $169.34 $169.34 

HALEY RACHEL $484.64 $484.64 

HALL DWAYNE $169.34 $169.34 

HAMER FRANCIS $248.15 $248.15 

HAMMAR BRIAN $1,669.46 $1,669.46 

HAMMOND JENNIFER $655.89 $655.89 

HAMMONDS STEPHANIE $503.40 $169.34 $672.74 

HANNAH MONICA $169.34 $169.34 

HARRINGTON THOMAS $3,263.63 $3,263.63 

HARRIS TONISHIA $706.23 $706.23 

HARROD MELISSA $169.34 $169.34 

HARTLEY KEVIN $1,537.65 $169.34 $1,706.99 

HARTWECK JR HAROLD $169.34 $169.34 

HARVEY WHITNEY $605.31 $605.31 

HASTINGS ANTHONY $169.34 $169.34 

HAYNES CATHY $169.34 $169.34 

HEARD DARRYELLE $982.34 $982.34 

HEDGEPETH RICHARD $169.34 $169.34 

HENEHAN MICHAEL $637.20 $637.20 

HENLEY CHRISTINA $1,537.65 $169.34 $1,706.99 

HERMAN JOSEPH $2,855.68 $2,855.68 

HETTLER CHRISTOPHER $1,757.32 $169.34 $1,926.66 

HICKS JENNIFER $541.08 $541.08 

HIGGANBOTHAM DEVIN $1,405.85 $169.34 $1,575.19 

HIGGINS RICHARD $1,669.46 $169.34 $1,838.80 

HIGGINS MICHELLE $393.67 $393.67 

HILL DOMINIQUE $169.34 $169.34 

HILL DAVID $169.34 $169.34 

HILYARD TYLER $370.48 $370.48 

HOARD LYNN $169.34 $169.34 

HOBBS IV WILLIAM $930.06 $930.06 

HOGAN BRYAN $169.34 $169.34 

HOGG ABEY $524.63 $524.63 

HOLEN BENJAMIN $169.34 $169.34 

HOOD SUSAN $1,645.35 $169.34 $1,814.69 

HOOVER BARBARA $169.34 $169.34 

HOWELL PATRICIA $169.34 $169.34 

HSIEH LEAH $160.60 $160.60 

HUBERT ANTHONY $169.34 $169.34 

HUMENIK NICHOLE $696.65 $696.65 

HUNTT RYAN $625.72 $625.72 

HUTSON CURTIS $169.34 $169.34 

HYND LINDA $978.50 $978.50 

JACKSON CHAD $169.34 $169.34 

JACKSON ROBYN $557.17 $557.17 

JACKSON GREGORY $610.88 $610.88 

JACOBS SALLY $448.97 $448.97 

JAKUBCZYK TOBIASZ $490.68 $490.68 

JANAS DAVID $662.81 $662.81 

4





JANKS ALEXANDER $206.68 $206.68 

JANOYAN SONIA $1,669.46 $169.34 $1,838.80 

JARVIS V CASPER $367.05 $367.05 

JENKINS DIANE $1,404.91 $1,404.91 

JEWELL CHRISTINA $1,669.46 $169.34 $1,838.80 

JOHNS CREIGHTON $1,591.02 $169.34 $1,760.36 

JOHNSON KEITH $169.34 $169.34 

JOHNSON THOMAS $169.34 $169.34 

JOHNSON KAREN $169.34 $169.34 

JOHNSTON EVERETT $555.45 $555.45 

JOINER ABOUELFAIOUD STEPHANIE $501.92 $501.92 

JONES CONNIE $169.34 $169.34 

JONES DWAYNE $169.34 $169.34 

JONES CHRISTOPHER $1,551.08 $169.34 $1,720.42 

JONES JR KENNETH $602.24 $602.24 

JORKASKY III RICHARD $1,427.82 $169.34 $1,597.16 

KARABINUS WILLIAM $169.34 $169.34 

KARISH JUSTIN $470.09 $470.09 

KAUFFMAN BENJAMIN $1,550.22 $169.34 $1,719.56 

KEIFFER AMBER $593.19 $593.19 

KEITH DUSTEN $169.34 $169.34 

KELLEHER SEAN $1,550.21 $169.34 $1,719.55 

KELLEY MARYON $240.40 $240.40 

KELLY JOSEPH $587.39 $587.39 

KENTZ GREGORY $1,581.61 $169.34 $1,750.95 

KERN NIKOLE $169.34 $169.34 

KETTLEWELL STEVEN $610.37 $169.34 $779.70 

KILGORE CLAYTON $169.34 $169.34 

KILGORE CLAYTON $1,669.46 $1,669.46 

KINNEY CHRISTOPHER $1,405.85 $169.34 $1,575.19 

KIROUAC MICHAEL $169.34 $169.34 

KLOVSKI KATRINA $169.34 $169.34 

KNISELY STEPHEN $235.02 $235.02 

KOEHLER KATHERINE $542.56 $542.56 

KOPELOW MARK $1,550.21 $169.34 $1,719.55 

KORPASH ANDREW $18.52 $18.52 

KOWALSKI AARON $641.81 $641.81 

KRAATZ MATTHEW $236.61 $236.61 

KRIESHER JAMES $633.47 $633.47 

KRIVOSHEY ADAM $483.34 $483.34 

KRIVOSHEY ALAN $3,734.34 $3,734.34 

KUNA LYNN $585.91 $585.91 

KURTZ SHARON $1,713.42 $1,713.42 

KUXHAUSEN AMANDA $1,631.80 $169.34 $1,801.14 

LAGAMBINA MICHAEL $556.04 $556.04 

LAHOUD STEVEN $586.74 $586.74 

LAMBAKIS MATTHEW $552.26 $552.26 

LANDES BRIDGETT $537.41 $537.41 

LARSEN JENNIFER $373.02 $373.02 

LASKO JEFFREY $573.20 $573.20 

LASKOSKI CAROL $492.16 $492.16 

LASPINA ROBERT $20.70 $20.70 

LAUB BARRY $570.65 $570.65 

LAYLIN JEFFREY $183.67 $183.67 

LEACH JASON $700.55 $700.55 

LEAHY GABRIELLE $367.46 $367.46 

LEE SCOT $1,647.50 $1,647.50 

LEONOV IGOR $419.10 $419.10 

LESAK ANDREW $4,014.68 $4,014.68 

LEWELLEN KENNETH $337.88 $337.88 

LEWIS STACEY $1,305.44 $169.34 $1,474.78 

LEWIS CHRISTINA $447.20 $447.20 

5





LEWISON MICHAEL $169.34 $169.34 

LIGHT TIMOTHY $2,855.68 $2,855.68 

LINK RICHARD $1,842.35 $169.34 $2,011.69 

LINN RICHARD $1,669.46 $169.34 $1,838.80 

LIPNICK SCOTT $1,044.77 $169.34 $1,214.11 

LOCKETT III CARL $1,385.09 $169.34 $1,554.43 

LOHMAR DANNY $169.34 $169.34 

LOMBARDO CRYSTAL $570.12 $570.12 

LOOMIS RAYMOND $1,647.50 $169.34 $1,816.84 

LOPEZ LEONARD $1,669.46 $169.34 $1,838.80 

LOPEZ REINALDO $612.42 $612.42 

LUBAS JOHN $1,537.99 $169.34 $1,707.33 

LUCAS AMANDA $578.93 $169.34 $748.27 

LUKANS BRETT $1,550.22 $169.34 $1,719.56 

LYNCH CHRISTOPHER $169.34 $169.34 

LYNN GREG $169.34 $169.34 

MANOS DANIEL $3,075.35 $3,075.35 

MARINO STEFANO $1,192.48 $169.34 $1,361.82 

MARINO HEATHER $1,669.46 $169.34 $1,838.80 

MARLER CORY $659.15 $659.15 

MARLIN SHAWN $578.11 $578.11 

MARSHALL WILLIAM $169.34 $169.34 

MASTELLONE LINDA $762.97 $762.97 

MASYUK STEPAN $651.75 $651.75 

MATTHEWS MATEA $169.34 $169.34 

MAXWELL ALLYSON $2,306.51 $2,306.51 

MAXWELL SEAN $475.65 $475.65 

McARTHUR PAUL $1,405.85 $169.34 $1,575.19 

MCCALLISTER TERRY $1,669.46 $169.34 $1,838.80 

MCCALLISTER SHARON $215.79 $215.79 

MCCLELLAND CHRISTOPHER $169.34 $169.34 

MCGEE LISA $169.34 $169.34 

MCGEE PATRICK $1,192.48 $169.34 $1,361.82 

MCGEE MICHELLE $169.34 $169.34 

MCGOWAN CATHLYN $1,537.65 $169.34 $1,706.99 

MCGRATH THEODORE $169.34 $169.34 

MCGREW CIARA $1,405.85 $169.34 $1,575.19 

MCGUIRE ROBERT $169.34 $169.34 

MCKENZIE KENNITH $528.83 $528.83 

MCLANE RACHEL $1,600.45 $169.34 $1,769.79 

MCMAHAN BRANDON $169.34 $169.34 

MCMURRAY RANDY $169.34 $169.34 

MEEUWEN ANDREW $47.38 $47.38 

MELEWSKI PETER $169.34 $169.34 

MENDOZA RICHARD $169.34 $169.34 

METOYER JENNIFER $560.42 $560.42 

MEYER JOHN $169.34 $169.34 

MEYER ERIC $516.17 $516.17 

MICHELON LARRY $453.29 $453.29 

MIDDLETON PATRICK $169.34 $169.34 

MILES JOHN $1,631.80 $169.34 $1,801.14 

MILES JIM $169.34 $169.34 

MILES MATHEW $573.20 $573.20 

MILICIA ROBERT $598.87 $598.87 

MILLER LAWRENCE $169.34 $169.34 

MISTECKA MEGAN $1,669.46 $169.34 $1,838.80 

MITCHELL HOLLIE $169.34 $169.34 

MOCZ MATTHEW $574.91 $574.91 

MOHRMANN KEITH $368.58 $368.58 

MONASTYRENKO EVGENI $95.36 $95.36 

MONK MATTHEW $588.46 $588.46 

MONROE PERRY $1,581.61 $169.34 $1,750.95 

6





MONROE PHILLIP $2,855.68 $2,855.68 

MOORE LORI $169.34 $169.34 

MOORE III ALVIN $169.34 $169.34 

MORELL ZACHARY $1,037.18 $1,037.18 

MORELL JAMES $4,014.68 $4,014.68 

MORGAN NEIL $621.70 $621.70 

MORGAN DAYNE $2,284.55 $2,284.55 

MORRIS TRAYVEOWNE $492.45 $492.45 

MOSEE JAMES $577.28 $577.28 

MOTES RUSSELL $169.34 $169.34 

MOYER JOANNE $169.34 $169.34 

MULL KATRINA $169.34 $169.34 

MURACO LAURA $2,548.12 $2,548.12 

MURPHY JR DANIEL $169.34 $169.34 

MURRAY VINCENT $169.34 $169.34 

NAGEL RON $169.34 $169.34 

NAGEL CHRISTINA $1,311.73 $169.34 $1,481.07 

NEEDHAM JR. LAWRENCE $1,669.46 $169.34 $1,838.80 

NESBIT JR WAYNE $1,623.97 $169.34 $1,793.31 

NGUYEN HIEU $478.67 $478.67 

NICHOLS TIFFANY $1,073.21 $169.34 $1,242.55 

NICHOLS MATTHEW $1,976.99 $1,976.99 

NICHOLSON LEON $1,669.46 $169.34 $1,838.80 

NICKLESS KIMBERLY $627.20 $627.20 

NIGRELLI MATTHEW $762.83 $762.83 

NITTO RICHARD $169.34 $169.34 

NOLL DEREK $324.04 $324.04 

NORMAN JONATHAN $169.34 $169.34 

NORRIS TIMOTHY $517.95 $517.95 

O DONNELL BRIAN $169.34 $169.34 

O DONNELL MIKE $1,559.61 $169.34 $1,728.95 

OBEIDAT AMANDA $19.05 $19.05 

OJAMETS RIINO $169.34 $169.34 

OPALINSKI BRIAN $1,647.48 $169.34 $1,816.82 

OPYRCHAL JUSTIN $1,550.22 $169.34 $1,719.56 

OSMANI RAFFEY $169.34 $169.34 

OSTERHOUDT FRANK $169.34 $169.34 

OWEN ANGELA $634.95 $634.95 

OWENS STEPHANIE $1,669.46 $169.34 $1,838.80 

OWENS ANDREW $443.06 $443.06 

OWSIK EDWARD $599.76 $169.34 $769.10 

PACIMEO TRACY $1,305.44 $169.34 $1,474.78 

PAHEL ALLEN $567.70 $567.70 

PALISWAT BRAD $2,196.65 $2,196.65 

PALLONE BENJAMIN $404.79 $404.79 

PAMPUSH JUSTIN $1,164.91 $1,164.91 

PANICO JOHN $169.34 $169.34 

PARKER R JASON $1,669.46 $169.34 $1,838.80 

PARKER AMY $532.32 $532.32 

PATEL SAMIR $169.34 $169.34 

PATRICK STEPHEN $521.14 $521.14 

PEABODY KYLE $607.03 $607.03 

PEARCE DAVID $662.40 $662.40 

PEARSON SHEFTON $411.41 $411.41 

PEDRAZA AMANDA $1,405.85 $169.34 $1,575.19 

PENA CRISTA $548.17 $548.17 

PENNINGTON KEITH $169.34 $169.34 

PERSSON SCOTT $510.67 $510.67 

PETERS JON $169.34 $169.34 

PETERS ROBERT $486.83 $486.83 

PETERSEN BRIAN $169.34 $169.34 

PETERSEN KIM $216.86 $216.86 

7





PHELPS JEREMY $2,416.32 $169.34 $2,585.66 

PHILLIPS BRAIN $169.34 $169.34 

PHILLIPS KAYLA $488.78 $169.34 $658.12 

PHILLIPS LORA $653.94 $653.94 

PIENDZIK BRANDON $169.34 $169.34 

PIERCE II JAMES $1,114.81 $169.34 $1,284.15 

PITTMAN JR GREGORY $352.67 $352.67 

PIZZINI DEBORAH $470.68 $169.34 $640.02 

PLANK GLENN $1,669.46 $169.34 $1,838.80 

POLCAR PAUL $1,669.46 $169.34 $1,838.80 

POOLE JORDAN $562.43 $562.43 

POOR SETH $169.34 $169.34 

POPE RANCE $169.34 $169.34 

PORTER KAREN $628.39 $628.39 

PRATT KEVIN $169.34 $169.34 

PRICE CHRISTOPHER $4,014.68 $4,014.68 

PUGH DARNELL $546.81 $169.34 $716.15 

PYE DAVID $4,014.68 $4,014.68 

QUANDT KATHRYN $164.86 $164.86 

QUERASHI RAHMAN $509.19 $509.19 

QUIGLEY RALPH $169.34 $169.34 

QUIRK SEAN $505.35 $505.35 

QUIRK KELLY $592.54 $592.54 

RACZ MICHAEL $193.02 $193.02 

RAINEY-CAMERON THELMA $504.99 $504.99 

REDFORD SONYA $370.77 $370.77 

REED MARION $987.86 $987.86 

REESE CHENE $169.34 $169.34 

REESE CHENE $1,537.65 $1,537.65 

REPICKY MARK $169.34 $169.34 

REYNOLDS HEATHER $2,855.68 $2,855.68 

RICHARDSON KELLIE $348.31 $169.34 $517.65 

RICHESIN CHARLIE $169.34 $169.34 

RICHEY KEVIN $169.34 $169.34 

RICHTER MICHELLE $1,581.61 $169.34 $1,750.95 

RICKMAN JEFFERY $169.34 $169.34 

RIGLER SHANNON $1,165.49 $1,165.49 

ROBERTS CHARLES $169.34 $169.34 

ROEDER ERIC $536.70 $169.34 $706.04 

ROGERS AMANDA $511.85 $511.85 

ROGERS JOHNSON KAREN $169.34 $169.34 

ROGOVITZ BRIAN $1,550.22 $169.34 $1,719.56 

ROGOVITZ ERIC $406.56 $406.56 

ROMERO MANUEL $169.34 $169.34 

RONKY ROBERT $1,550.22 $169.34 $1,719.56 

ROSENBERG ALBERT $1,669.46 $169.34 $1,838.80 

ROSTA MICHELE $1,587.86 $169.34 $1,757.20 

ROTHACKER GREGORY $1,625.52 $169.34 $1,794.86 

ROULSTON ANTHONY $1,550.22 $169.34 $1,719.56 

ROUTMAN MITCHELL $32.12 $32.12 

ROX MELODY $1,537.65 $169.34 $1,706.99 

RUFENER WENDY $1,943.81 $1,943.81 

RUMSEY ROBERT $169.34 $169.34 

RUSHING SUSAN $496.18 $496.18 

RYDBOM CALVIN $169.34 $169.34 

SABIO ANDREW $1,550.22 $169.34 $1,719.56 

SAFFER JASON $169.34 $169.34 

SAIENNI VINCENT $169.34 $169.34 

SALERNO STEVEN $2,723.88 $2,723.88 

SAUNDERS DANA $169.34 $169.34 

SAVAGE DEREK $764.14 $764.14 

SAVOY ASHTON $423.89 $423.89 

8





SCHLACHTA ROBERT $528.95 $528.95 

SCHLOSSER THERESA $4,014.68 $4,014.68 

SCHMEHL CHRISTIAN $1,405.85 $169.34 $1,575.19 

SCHMIDT DUANE $169.34 $169.34 

SCHUHWERK ERIK $169.34 $169.34 

SCOTT JUSTIN $218.87 $218.87 

SCRUTON JAMES $1,625.52 $169.34 $1,794.86 

SEACREST CHAD $169.34 $169.34 

SEAGER DAVID $4,014.68 $4,014.68 

SEARS LESLIE $402.12 $402.12 

SEITZINGER GEORGE $3,954.01 $3,954.01 

SEMAN CRAIG $3,075.34 $3,075.34 

SESTITO JUSTIN $606.03 $606.03 

SHARIN ALBERT $3,514.67 $3,514.67 

SHARPE JUSTIN $1,506.27 $169.34 $1,675.61 

SHAUGHNESSY ANNE $646.55 $646.55 

SHAWKI MICHAEL $169.34 $169.34 

SHEPHERD WILLIAM $169.34 $169.34 

SHEPPARD ALFONSO $169.34 $169.34 

SHOTTE DANIEL $169.34 $169.34 

SHOWERS NANCY $43.30 $43.30 

SHULMAN DAWNMARIE $1,755.87 $169.34 $1,925.21 

SIGNORELLI LOUIS $132.27 $132.27 

SIMOES JAYSON $453.41 $453.41 

SIMS JR JAMES $648.32 $648.32 

SISTRUNK KATHRYN $1,407.43 $169.34 $1,576.77 

SMITH JUSTIN $169.34 $169.34 

SMITH DEANNA $489.20 $489.20 

SMITH JARVIS $114.64 $114.64 

SMITH JUSTIN $1,405.85 $1,405.85 

SMITH JULIE $3,295.01 $3,295.01 

SMITH DALE $474.59 $474.59 

SMITH JR ROBERT $4,014.68 $4,014.68 

SMYKSY MICHAEL $2,635.98 $2,635.98 

SNEIDERMAN MARC $2,416.31 $2,416.31 

SNYDER JOANNE $369.29 $369.29 

SOKOLOSKI ANTHONY $3,922.63 $3,922.63 

SOLLARS DAVID $527.23 $527.23 

SOVIAR II STEPHEN $418.10 $169.34 $587.44 

SPARKS ANDREW $185.86 $185.86 

SPICKENAGEL MARK $169.34 $169.34 

STECKY MATTHEW $536.23 $536.23 

STEIN JONATHAN $12.13 $12.13 

STEKO DARIO $329.49 $169.34 $498.83 

STELLA RYAN $625.13 $625.13 

STEPHENS BETH $257.20 $257.20 

STEVENS CHRIS $169.34 $169.34 

STEWART NATALIE $169.34 $169.34 

STEYSKAL REX $351.79 $351.79 

STOGDILL TERRY $169.34 $169.34 

STOTT ROBERT $1,550.21 $169.34 $1,719.55 

STRODE JR ARTHUR $348.71 $348.71 

STUCKERT MICHAEL $531.14 $531.14 

STUCKERT DAVIS HOLLY $621.52 $621.52 

STULL GENEVIEVE $359.95 $359.95 

STURDY SARA $472.87 $472.87 

SURVOY GARY $169.34 $169.34 

TEAGUE STEVEN $470.09 $470.09 

THOMAS GLENN $169.34 $169.34 

THOMAS JESSICA $1,550.22 $169.34 $1,719.56 

THOMPSON BOBBY $659.26 $169.34 $828.60 

THOMPSON JOHN $565.33 $565.33 

9





THOMPSON II ROBERT $2,855.68 $2,855.68 

TOBER CLAYTON $421.53 $421.53 

TODD KENNETH $1,305.44 $169.34 $1,474.78 

TOKARCIK PATRICIA $4,014.68 $4,014.68 

TOVAR REGINA $1,694.58 $169.34 $1,863.92 

TRAVIS COREY $571.60 $571.60 

TROCHE DARREN $566.99 $566.99 

TUCCIARONE ANTHONY $1,305.44 $169.34 $1,474.78 

TUCKER JOHNATHAN $169.34 $169.34 

TURNER JASON $1,205.02 $169.34 $1,374.36 

TYLER SHAWN $371.13 $371.13 

UNGER JOHN $169.34 $169.34 

UNTHANK NICHOLAS $675.65 $675.65 

URBAN MORTON $552.08 $552.08 

URBANO CAROLINE $1,581.61 $169.34 $1,750.95 

URMETZ PATRICIA $2,996.25 $2,996.25 

USOCCHI MICHAEL $93.28 $93.28 

VANEVERY MATTHEW $1,405.85 $169.34 $1,575.19 

VARAGONA JAMES $1,537.65 $169.34 $1,706.99 

VASSALLO MARIA $169.34 $169.34 

VASSALLO MARIA $1,537.65 $1,537.65 

VASSMER FALISHA $589.35 $589.35 

VENER COLLEEN $514.69 $514.69 

VENTURA LYDIA $1,407.43 $169.34 $1,576.77 

VENTURA ANTHONY $1,515.70 $1,515.70 

VOGEL CASEY $277.43 $277.43 

VROMAN JOSHUA $568.70 $568.70 

WADE JULIE $1,537.65 $169.34 $1,706.99 

WADE MARCUS $351.08 $351.08 

WALKER MELANIE $1,669.46 $169.34 $1,838.80 

WALKER CHANDA $319.13 $319.13 

WALLACE JAMAR $169.34 $169.34 

WALTON DAVID $251.99 $251.99 

WALTON JR GRADY $1,669.46 $169.34 $1,838.80 

WARD PHILIP $639.15 $639.15 

WARNER LANIRA $531.38 $531.38 

WARREN MELANIE $1,355.67 $169.34 $1,525.00 

WATSON JAMES $169.34 $169.34 

WECHSLER STEVEN $169.34 $169.34 

WEEDEN DUJUANE $669.14 $669.14 

WEEKS TIFFANY $496.42 $496.42 

WELSH DAVID $1,603.56 $169.34 $1,772.90 

WESP II DAVID $891.92 $169.34 $1,061.26 

WESSON TYRUS $169.34 $169.34 

WESTOVER LEONA $568.35 $568.35 

WHITE TAMARIA $169.34 $169.34 

WHITE WILLIAM $628.27 $628.27 

WHITE JAY $642.76 $642.76 

WIENSZCZAK ERIC $1,537.65 $169.34 $1,706.99 

WILDT KRISTIN $1,407.43 $169.34 $1,576.77 

WILKEN DEBRA $169.34 $169.34 

WILLIAMS MARC $169.34 $169.34 

WILLIAMS KEVIN $276.54 $276.54 

WILLIAMS TAYLOR PAULETTE $169.34 $169.34 

WILSON GRADY $169.34 $169.34 

WILSON GERRY $538.77 $538.77 

WILSON LISA $650.98 $650.98 

WINDWILLOW CELINE $515.34 $515.34 

WINSLOW WADE $501.62 $501.62 

WISNIEWSKI ALEXANDER $663.41 $663.41 

WOLF BRIAN $1,625.52 $169.34 $1,794.86 

WOOD BRYAN $652.34 $652.34 

10





WOODALL AMANDA $311.86 $311.86 

WRIGHT AARON $169.34 $169.34 

WRIGHT JERRY $1,537.65 $169.34 $1,706.99 

YGLECIAS STACY $1,616.11 $169.34 $1,785.45 

YOUNG MATTHEW $657.67 $657.67 

YOUNT DIANA $3,159.43 $3,159.43 

YUROCKO DEBBIE $169.34 $169.34 

ZETAH ERIC $169.34 $169.34 

ZICKWOLF KENNETH $1,653.95 $169.34 $1,823.28 

TOTAL $484,650 $53,850 $538,500 

11





) 

) 

and 

) 

) 


) 

) 

On behalf of themselves and all ) 


) 

) 

Plaintiffs, ) 

) 

v. 

) 

) 

MARK RACE, JOHN BULGARELLA, ) 

DALE FULLER, B. CHARLES AMES, ) 

HARVEY SANDERS AND NORBERT ) 

LEWANDOWSKI, 

) 

) 

Defendants. ) 

************************************ ) 


) 

) 

and 

) 

) 


) 

) 


others similarly situated, 

) 

) 

Plaintiffs, ) 

) 

v. 

) 

) 

DIRK KETTLEWELL 

) 

) 

and 

) 

) 

DAWN CALLAHAN-KETTLEWELL, ) 

) 

Defendants. ) 

) 

************************************ 

CASE NO. 1:09-CV-2670 

CASE NO. 1:09-CV-2285 



FIRST STIPULATED ORDER AND 

PARTIAL FINAL JUDGMENT 

Exhibit 5

These matters are before the Court on the parties’ Joint Motion for Approval of 

Settlement (“Joint Motion”) pursuant to § 16(b) of the Fair Labor Standards Act (“FLSA”), 29 

U.S.C. § 216(b). The Joint Motion asks the Court to approve, as fair and reasonable, the 

proposed Settlement reached by the Parties and memorialized in the Agreement of Settlement 

and Release of Claims (“Settlement Agreement”) attached to the Joint Motion as Exhibit A. 

Having reviewed the Settlement Agreement and its Exhibits, the Declarations of Jason R. 

Bristol and Anthony J. Lazzaro appended to the Joint Motion, and the pleadings and papers on 

file in this Action, and for good cause established therein, the Court enters this First Stipulated 

Order and Partial Final Judgment approving the Settlement, the Settlement Agreement, and its 

Exhibits, including the proposed Notice, 1 the proposed Consent and Release Form, the proposed 

allocation and calculation of settlement payments, the proposed Service Awards to the Named 

Plaintiffs, and the proposed attorneys’ fees and expense reimbursements to Plaintiffs’ Counsel, 

as follows: 

1. The captioned Lawsuits assert wage-and-hour claims under the FLSA, 29 U.S.C. 

§§ 201-219, and various state laws, on behalf of former employees of InkStop, Inc. (“InkStop”). 

2. InkStop ceased business operations on October 2, 2009, leaving employees 

unpaid for work performed after September 13. On October 4, 2009, the first Lawsuit, Case No. 

1:09-cv-2285, was filed against InkStop and two of its Executive Officers, Dirk Kettlewell and 

Dawn Callahan-Kettlewell. On or about November 5, 2009 InkStop filed a Chapter 7 petition in 

the United States Bankruptcy Court for the Northern District of Ohio, captioned In re InkStop, 

Inc., Case No. 09-20524-rb. On November 13, 2009 InkStop was dropped as a defendant in the 

first Lawsuit. Also on November 13, 2009, the second Lawsuit, Case No. 1:09-cv-2670, was 

filed against other Executive Officers and Directors. 

1 Terms defined in the Settlement Agreement have the same meaning in this Order as in the Settlement Agreement. 

2

3. The Named Plaintiffs in the Lawsuits are Melanie Warren, who worked for 

InkStop as a Store Manager, and Carol Laskoski, who worked as an Assistant Store Lead. The 

Lawsuits were brought as collective actions under the FLSA on behalf of the Named Plaintiffs 

and all others similarly situated. As of the filing of the Joint Motion, 237 additional employees 

had already opted into the Lawsuits by submitting consent forms filed with the Court (“Existing 

Opt-In Plaintiffs”). 

4. The Lawsuits assert identical claims under the FLSA and various state laws on 

behalf of two groups of employees, the Non-Payment Group and the Store Manager Group. For 

the Non-Payment Group, Plaintiffs seek compensation for both hourly and salaried employees 

for the unpaid work performed after September 13, 2009. For the Store Manager Group, 

Plaintiffs allege that salaried employees who worked as Store Managers after January 7, 2008 

were improperly classified as “exempt” from overtime compensation and are owed unpaid 

overtime compensation. 

5. Plaintiffs allege that Defendants were “employers” within the meaning of § 

203(d) of the FLSA, in that they were “person[s who] act[ed] directly or indirectly in the interest 

of an employer,” InkStop, “in relation to employees,” including Plaintiffs and other similarly- 

situated employees. Defendants in each case all deny that they are “employers” as defined in the 

FLSA and, further, deny any liability or wrongdoing of any nature. 

6. The parties have acknowledged that should these cases proceed, many bona fide 

disputes over legal and factual issues will have to be litigated, the ultimate resolution of which 

will substantially impact the outcome of these matters. Such bona fide disputes include: 

a) Whether the individual Defendants can be held personally liable under the 

FLSA in the circumstances existing here; 

b) Whether these matters should be stayed in light of the fact that Inkstop, the 

employing entity, is in bankruptcy proceedings; 

3

c) Whether the Store Managers perform duties and responsibilities 

establishing their exempt status under the FLSA; 

d) Whether the actions of Defendants at relevant times were taken in good 

faith; and 

e) Whether the Court should exercise supplemental jurisdiction of the state 

law claims pleaded. 

7. Settlement negotiations in these cases spanned four months and consumed many 

hours. The negotiations began in late December and continued through January and February, 

and several written proposals were exchanged in that period. The U.S. Department of Labor 

assisted the parties during these negotiations. 

8. The Parties reached an agreement in principle on March 4, 2010. The proposed 

Settlement eliminates the time, cost, and uncertainty of further litigation. In addition, given the 

financial condition of Inkstop and the current bankruptcy proceedings, the proposed Settlement 

is likely to be the only avenue for the former employees of Inkstop to timely recover any amount. 

9. The proposed Settlement will cover the Named Plaintiffs and the 237 Existing 

Opt-In Plaintiffs, as well as all other eligible employees (“Other Eligible Settlement 

Participants”) who elect to participate in the Settlement by signing and returning the Consent and 

Release Form. The total settlement amount of $660,000 (“Total Eligible Amount”), after 

deductions approved by the Court, will be divided into Individual Payments. Ninety percent of 

the Total Eligible Amount will be allocated to the payment of unpaid wages after September 13, 

2009. The Individual Payments to the respective participants in this category consist of their 

recoverable unpaid wages under the FLSA as calculated by the U.S. Department of Labor less 

the allocation to InkStop Store Managers, subject to a cap of $4,920.50. Ten percent of the Total 

Eligible Amount will be allocated to persons who worked for InkStop as Store Managers after 

January 7, 2008. The Individual Payment in this category will be a per capita payment in the 

4

amount $166.72. Participants who fall within both groups are eligible for Individual Payments in 

each of the two categories. The proposed deductions include attorneys’ fees in the amount of 

16.66% of the Total Eligible Amount, as well as reimbursements of litigation expenses in the 

amount of $6,500 and Service Awards of $2,500 each to the Named Plaintiffs for their service in 

the Lawsuits. In addition, income taxes and other withholdings will be deducted from each 

Individual Payment in accordance with law. 

10. To be eligible for Individual Payments, the Named Plaintiffs, Existing Opt-In 

Plaintiffs, and Other Eligible Settlement Participants must sign and return the Consent and 

Release Form by the Early Deadline or the Final Deadline. The Notice and attached Consent and 

Release Form will be mailed to the Existing Opt-In Plaintiffs and the Other Eligible Settlement 

Participants. The Early Deadline is the later of twenty-one days after the date of mailing of the 

Notice or the date signed Consent and Release Forms have been received from the Named 

Plaintiffs and at least ninety percent of the Existing Opt-In Plaintiffs or fifty percent of the 

Existing Opt-In Plaintiffs and Other Eligible Settlement Participants combined. The Final 

Deadline is ninety days after the date of mailing of the Notice, but may be extended for an 

additional thirty days. 

11. The Settlement Agreement provides that, in consideration of the Total Eligible 

Amount and these Individual Payments, the claims of the Named Plaintiffs and all Existing Opt- 

In Plaintiffs are to be dismissed with prejudice, as will the claims of all Other Eligible Settlement 

Participants who elect to participate in the Settlement by signing and returning the Consent and 

Release Form. In addition, participants’ claims in the InkStop bankruptcy will be withdrawn. 

12. The Court finds that the proposed Settlement is fair and reasonable and satisfies 

the standard for approval under § 16(b) of the FLSA, 29 U.S.C. § 216(b). The Court finds that 

the Settlement Agreement resolves a bona fide dispute under the FLSA, and resulted from arms- 

5

length negotiations between experienced counsel after substantial investigation. Plaintiffs’ 

Counsel have informed the Court that they believe the Settlement is fair, reasonable, and 

adequate and in the best interests of the Named Plaintiffs, the Existing Opt-In Plaintiffs, and 

Other Eligible Settlement Participants. The Court has considered all relevant factors, including 

the risk, complexity, expense, and likely duration of the litigation; the extent of investigation and 

the stage of the proceedings; the amount offered in the Settlement; and the experience and views 

of counsel for the Parties. 

13. The Court approves the Settlement Agreement and its Exhibits, including the 

proposed Notice and the proposed Consent and Release Form, and orders that the Settlement be 

implemented according to the terms and conditions of the Settlement Agreement and as directed 

herein. The Court grants final approval of the Settlement as to the Named Plaintiffs and all 

Existing Opt-In Plaintiffs. As all Other Eligible Settlement Participants, the Court grants 

preliminary approval of the Settlement and directs that they be given Notice as provided in the 

Settlement Agreement. 

14. The Court finds that the proposed allocation and calculation of Individual 

Payments are fair and reasonable. The Court approves the method of calculation and proposed 

distribution of Individual Payments. The Parties have submitted with the Joint Motion a 

Schedule of Individual Payments listing the names of all eligible participants and the Individual 

Payments for which they are eligible. The Court approves the Schedule of Individual Payments 

and orders that such payments be distributed in the manner, and subject to the terms and 

conditions, set forth in the Settlement Agreement. 

15. The Court approves the Service Awards to the Named Plaintiffs in recognition of 

their service in the Lawsuits, and orders that such payments be made in the manner, and subject 

to the terms and conditions, set forth in the Settlement Agreement. 

6

16. The Court approves the payment of attorneys’ fees and expense reimbursements 

to Plaintiffs’ Counsel as provided in the Settlement Agreement, and orders that such payments be 

made in the manner, and subject to the terms and conditions, set forth in the Settlement 

Agreement. 

17. The Court dismisses the claims of the Named Plaintiffs and the Existing Opt-In 

Plaintiffs with prejudice, and enters final judgment dismissing them from the Lawsuits. The 

Court finds there is no just reason for delay and directs the Clerk of the Court to enter this First 

Stipulated Order and Partial Final Judgment immediately. 

18. The Court retains jurisdiction over the Lawsuits for purposes of administration of 

the Settlement and enforcement of the Settlement Agreement. 

Date: _________________________ 

/s/ Jason R. Bristol 

JASON R. BRISTOL (0072989) 

jbristol@crklaw.com 

THOMAS A. DOWNIE (0033119) 

tdownie@crklaw.com 

COHEN ROSENTHAL & KRAMER LLP 

The Hoyt Block Building – Suite 400 

700 West St. Clair Avenue 

Cleveland, OH 44113 

(216) 781-7956 [Telephone] 

(216) 781-8061 [Facsimile] 

7 

SO ORDERED: 

___________________________________ 

Solomon Oliver 

United States District Judge 

SO STIPULATED: 

/s/ Mitchell G. Blair 

MITCHELL G. BLAIR (0010892) 

mblair@calfee.com 

JOHN R. CERNELICH (0034697) 

jcernelich@calfee.com 

CALFEE, HALTER & GRISWOLD LLP 

1400 KeyBank Center 

800 Superior Avenue 


(216) 622-8200 [Telephone] 

(216) 241-0816 [Facsimile]

s/ Anthony J. Lazzaro 

ANTHONY J. LAZZARO (0077962) 

anthony@lazzarolawfirm.com 

THE LAZZARO LAW FIRM, LLC 

920 Rockefeller Building 

614 W. Superior Avenue 


(216) 696-5000 [Telephone] 

(216) 696-7005 [Facsimile] 

Attorneys for Named Plaintiffs 

8 

/s/ Vilia B. Hayes 

VILIA B. HAYES 

(New York Registration No. 1721976) 

hayes@hugheshubbard.com 

HUGHES HUBBARD & REED LLP 

One Battery Park Plaza 

New York, NY 10004-1482 

(212) 837-6000 [Telephone] 

(212) 422-4726 [Facsimile] 

Attorneys for Defendants 

/s/ Maynard A. Buck 

MAYNARD A. BUCK (0022423) 

PATRICK O. PETERS (0079539) 

BENESCH, FRIEDLANDER, 

COPLAN & ARONOFF LLP 

200 Public Square, Suite 2300 

Cleveland, Ohio 44114-2378 

Telephone: (216) 363-4500 

Facsimile: (216) 363-4588 

E-mail: mbuck@beneschlaw.com 

ppeters@beneschlaw.com 

Attorneys for Defendants Dirk Kettlewell, 

Dawn Callahan-Kettlewell, Dale Fuller, 

Mark Race and John Bulgarella 

Dated: March 29, 2010 Dated: March 29, 2010

NOTICE OF SETTLEMENT OF INKSTOP LAWSUITS 

(with attached form to obtain a settlement payment) 

TO: All salaried and hourly employees of InkStop, Inc. who were not paid for work performed after 

September 13, 2009 (“the Non-Payment Group”); and all salaried Store Managers of InkStop, 

Inc. after January 7, 2008 (“the Store Manager Group”). 

FROM: Judge Oliver, United States District Court for the Northern District of Ohio. 

This Notice informs you of the settlement of wage-and-hour lawsuits by InkStop employees and provides you 

with a Settlement Form which you must sign and return to receive your settlement payment. 

1. INTRODUCTION AND SUMMARY 

The Settlement announced by this Notice makes substantial Settlement Payments available to all eligible 

employees of InkStop in the two groups defined above (the Non-Payment Group and the Store Manager 

Group). The Settlement is supported by Melanie Warren and Carol Laskoski, who serve as Representative 

Plaintiffs in the two federal lawsuits against Executive Officers and Directors of InkStop, and was negotiated by 

Plaintiffs’ Counsel who represent Warren, Laskoski, and 237 other InkStop employees in those cases. 

TO RECEIVE A SETTLEMENT PAYMENT, YOU MUST RETURN THE ATTACHED FORM 

2. THE INKSTOP LAWSUITS 

On October 2, 2009, InkStop, Inc. went out of business, leaving employees unpaid for work performed after 

September 13, 2009. On October 4, 2009, a lawsuit seeking payment for unpaid work was filed against InkStop 

and two of its Executive Officers. The lawsuit was filed by Representative Plaintiffs Melanie Warren, who had 

worked for InkStop as a Store Manager, and Carol Laskoski, who had worked as an Assistant Store Lead. On 

November 5, 2009, InkStop, Inc. filed a Chapter 7 bankruptcy petition. On November 13, 2009, InkStop was 

dropped as a defendant in the first lawsuit, and a second lawsuit was filed against other Executive Officers and 

Directors. 

The InkStop Lawsuits assert claims under the federal Fair Labor Standards Act and various state laws. For the 

Non-Payment Group defined above, the Lawsuits seek wages for both hourly and salaried employees for the 

unpaid work performed after September 13, 2009. For the Store Manager Group, the Lawsuits allege that 

salaried employees who worked as Store Managers after January 7, 2008 were improperly classified as “exempt” 

from overtime compensation are owed unpaid overtime compensation. 

3. THE SETTLEMENT 

The Settlement was reached between the Representative Plaintiffs and all the former members of InkStop’s 

Board of Directors, and has been approved by the U.S. District Court as fair, reasonable, and adequate. The 

Settlement is binding on the Representative Plaintiffs and the 237 former employees who previously opted into 

the lawsuits by submitting consent forms. In addition, the Settlement will include all other eligible employees 

who choose to participate by signing the attached form. The terms of the Settlement are summarized below. 

A. Settlement Payments to InkStop Employees and Released Claims 

The Total Settlement Amount is $660,000. That amount, after deductions approved by the Court, will be 

divided into Individual Payments to eligible employees as follows. Ninety percent (90%) will be allocated to 

employees in the Non-Payment Group, who are eligible for Individual Payments proportionate to their 

Exhibit 6

espective unpaid wages for work performed after September 13, 2009 as calculated by the Department of Labor, 

up to a maximum payment of $4,920.50. Ten percent (10%) will be allocated to employees in the Store Manager 

Group, who are eligible for a per person payment in the amount of $169.34. Store Managers who fall within 

both Groups are eligible for two Individual Payments, one from each category. 

The deductions approved by the Court include attorneys’ fees in the amount of 16.66% of the Total Settlement 

Amount. (To maximize the Individual Payments to employees, Plaintiffs’ Counsel chose to reduce their 

customary attorneys’ fee of 33.33% by one-half). The Court has also approved reimbursements of litigation 

expenses of approximately $6,500, and service awards of $2,500 each to the Representative Plaintiffs for their 

service in the lawsuits. 

In exchange, the InkStop Lawsuits will be dismissed, and participating employees will release all claims for 

unpaid wages under the Fair Labor Standards Act as well as state statutes and common law against InkStop, Inc. 

and any related persons and entities including its directors, officers, and employees. The released claims include 

any claims that were or could have been made in the InkStop Lawsuits, as well as any claims in the InkStop 

bankruptcy. 

B. Advantages of the Settlement and Plaintiffs’ Counsel’s Recommendation 

Plaintiffs’ Counsel strongly recommend the Settlement. It offers substantial settlement payments to employees, 

without the delay, uncertainty, and risk of continuing with the InkStop Lawsuits or awaiting the outcome of the 

InkStop bankruptcy (which may provide no recovery at all). Before deduction of attorneys’ fees, expenses, and 

service awards, participating employees in the Non-Payment Group will recover approximately 97.37% of their 

recoverable wages under the Fair Labor Standards Act. The individual payments to the Store Manager Group, 

although lower in amount, are fair and equitable considering the less certain nature of their claim for unpaid 

overtime compensation. 

4. HOW TO RECEIVE YOUR SETTLEMENT PAYMENT 

To participate in the settlement, you must complete and return the attached Settlement Form entitled 

“Consent to Opt-Into Lawsuit, Release and Dismiss Claims.” You can return the Settlement Form by: (a) 

mailing it to Plaintiffs’ Counsel in the enclosed self-addressed and postage-prepaid envelope; (b) faxing your 

signed Settlement Form to Plaintiffs’ Counsel at 216-696-7005; or (c) scanning your signed Settlement Form and 

emailing it to Plaintiffs’ Counsel at inkstop@lazzarolawfirm.com. 

5. PAYMENT DATES 

There are two payment dates. Eligible employees who returned signed Settlement Forms by the first 

deadline, April __, 2010, will receive settlement checks in approximately May, 2010. 

FORMS THAT ARE RETURNED BY APRIL ___, 2010 WILL RECEIVE PRIORITY. 

The final deadline for returning signed Settlement Forms is June __, 2010. Checks will be mailed at the 

conclusion of the case which is anticipated to be August or September 2010. 

5. FURTHER INFORMATION 

Further information about the settlement may be obtained from Plaintiffs’ Counsel: 

Jason R. Bristol, Cohen Rosenthal & Kramer LLP Anthony J. Lazzaro, The Lazzaro Law Firm, LLC 

216-781-7956 / jbristol@crklaw.com 

216-696-5000 / anthony@lazzarolawfirm.com 

PLEASE DO NOT CONTACT THE COURT. 

2

CONSENT TO OPT INTO LAWSUIT, RELEASE AND DISMISSAL OF CLAIMS 

I consent to opt into the lawsuits, Warren, et al. v. Race, et al., Case No. 1:09-CV-2670 (“the Lawsuit”) and 

Warren, et al. v. Kettlewell, et al., Case No. 1:09-CV-2285 (the “Related Lawsuit”) pending in the U.S. District Court 

for the Northern District of Ohio. I agree to be represented by Cohen, Rosenthal & Kramer LLP and The Lazzaro Law 

Firm, LLC, to be bound by the settlement, and fully and finally release any claims or rights I may have in connection 

the Lawsuit and Related Lawsuit. 

In exchange, I hereby release all wage and compensation claims – including, but not limited to, all claims for 

non-payment of wages, vacation pay, paid time off, and expense reimbursement – that I now have or may have, both 

known and unknown, against InkStop, Inc., its parent company(ies), subsidiaries, division, affiliated businesses, 

predecessors and assigns, if any, together with its and their respective past and present owners, stockholders, assigns, 

agents, directors, officers, employees, representatives, attorneys, benefit plans, plan fiduciaries and/or administrators, 

and all persons acting by, through, under, or in concert with any of them, including (but not limited to) any party that 

was or could have been named as a defendant in the Lawsuit or the Related Lawsuit (collectively, “Releasees”). I also 

hereby waive and release any compensation-related claims I have or may have in the bankruptcy proceedings 

involving InkStop, Inc. My releases and waivers include all claims under the Fair Labor Standards Act, 29 U.S.C. 

§201, et seq., and any applicable state laws. 

I understand that I will receive a one-time payment of $__________ (“Payment”), less federal and state tax 

withholdings and deductions required by law. 

I also hereby consent to the dismissal of the Lawsuit and the Related Lawsuit and any and all claims that were 

or could have been raised in the Lawsuit and the Related Lawsuit by and through the Named Plaintiffs and/or my 

above-approved legal counsel. I hereby designate counsel for the Named Plaintiffs to execute all appropriate 

documents to effectuate my payment and the settlement of the Lawsuit or the Related Lawsuit. 

I have carefully read and fully understand all items in this agreement and am voluntarily signing it. I 

understand that if I have any questions, I know I have the right to discuss this agreement with my own private 

attorney. I also understand that any issues relating to this agreement will be addressed under the laws of the State of 

Ohio. 

PLEASE READ AND CONSIDER THIS AGREEMENT CAREFULLY BEFORE EXECUTING. THIS 

AGREEMENT INCLUDES A RELEASE OF ALL WAGE AND COMPENSATION CLAIMS. 

 

 

 

___________________________________ 

Signature 

___________________________________ 

Social Security No. (required for a payment) 

___________________________________ 

Date 

FAX to: 216-696-7005 

E-MAIL to: inkstop@lazzarolawfirm.com; or 

MAIL to: InkStop Settlement 

c/o The Lazzaro Law Firm, LLC 




3 

Name/Address Corrections: 

___________________________________ 

___________________________________ 

___________________________________ 

___________________________________ 

Phone Number 

___________________________________ 

Email Address 

On or before April __, 2010 to receive priority. 

The final deadline is June __, 2010.





) 

) 

and 

) 

) 


) 

) 



) 

) 

Plaintiffs, ) 

) 

v. 

) 

) 




LEWANDOWSKI, 

) 

) 

Defendants. ) 

************************************ ) 


) 

) 

and 

) 

) 


) 

) 



) 

) 

Plaintiffs. ) 

) 

v. 

) 

) 


) 

) 

and 

) 

) 


) 

Defendants. ) 

) 

************************************ 

CASE NO. 1:09-CV-2670 

CASE NO. 1:09-CV-2285 



SECOND STIPULATED ORDER AND 

PARTIAL FINAL JUDGMENT 

Exhibit 7

1. The Court previously granted the Parties’ Joint Motion for Approval of 


U.S.C. § 216(b). 

2. In its First Stipulated Order and Partial Final Judgment (“First Stipulated Order”), 

the Court approved the Settlement Agreement as fair and reasonable, granted final approval of 

the Settlement as to the Named Plaintiffs and the Existing Opt-In Plaintiffs, 1 and granted 

preliminary approval of the Settlement as to the Other Eligible Settlement Participants. 

3. The Settlement makes Individual Payments available to the Named Plaintiffs, the 

Existing Opt-In Plaintiffs, and Other Eligible Settlement Participants who sign and return the 

Consent and Release Form by the Early Deadline or the Final Deadline. The First Stipulated 

Order directed that the Notice and attached Consent and Release Form be mailed to the Existing 

Opt-In Plaintiffs and the Other Eligible Settlement Participants as provided in the Settlement 

Agreement. 

4. As contemplated by the Settlement Agreement and the First Stipulated Order, the 

Parties have submitted this Second Stipulated Order and Partial Final Judgment, and have 

attached to it (i) lists of all Named Plaintiffs, Existing Opt-In Plaintiffs, and Other Eligible 

Settlement Participants who returned signed Consent and Release Forms on or before the Early 

Deadline, and (ii) copies of those individuals’ signed Consent and Release Forms (from which 

their addresses and social security numbers will be redacted). 

5. As to the Existing Opt-In Plaintiffs so listed, the Court approves the issuance of 

Individual Payments to them in accordance with, and subject to the terms and conditions of, the 



2

6. As to the Other Eligible Settlement Participants so listed, the Court grants final 

approval of the Settlement, and approves the issuance of Individual Payments to them in 

accordance with, and subject to the terms and conditions of, the Settlement Agreement. 

7. The Court approves the issuance of (i) Service Awards to the Named Plaintiffs of 

$2,500 each in recognition of their service as representative plaintiffs, less deductions as 

provided in the Settlement Agreement, (ii) attorneys’ fees to Plaintiffs’ Counsel in an amount 

equal to 16.66% of the Individual Payments issued to the Named Plaintiffs and to the Existing 

Opt-In Plaintiffs and Other Eligible Settlement Participants listed in this Second Stipulated 

Order, and (iv) expense reimbursements to Plaintiffs’ Counsel in the amount of $6,500. 

8. The Court dismisses with prejudice the claims of the Other Eligible Settlement 

Participants listed in this Second Stipulated Order, and enters final judgment dismissing them 

from the Lawsuits. The Court finds there is no just reason for delay and directs the Clerk of the 

Court to enter this Second Stipulated Order and Partial Final Judgment immediately. 

9. The Court continues to retain jurisdiction over the Lawsuits for purposes of 

administration of the Settlement and enforcement of the Settlement Agreement. 

Date: _________________________ 


3 

SO ORDERED: 

___________________________________ 




MITCHELL G. BLAIR (0010892)








(216) 781-7956 [Telephone] 

(216) 781-8061 [Facsimile] 







(216) 696-5000 [Telephone] 

(216) 696-7005 [Facsimile] 


4 


JOHN R. CERNELICH (0034697) 






(216) 622-8200 [Telephone] 

(216) 241-0816 [Facsimile] 






New York, NY 10004-1482 

(212) 837-6000 [Telephone] 

(212) 422-4726 [Facsimile] 








Telephone: (216) 363-4500 

Facsimile: (216) 363-4588 






Dated: March __, 2010 Dated: March __, 2010





) 

) 

and 

) 

) 


) 

) 



) 

) 

Plaintiffs, ) 

) 

v. 

) 

) 




LEWANDOWSKI, 

) 

) 

Defendants. ) 

************************************ ) 


) 

) 

and 

) 

) 


) 

) 



) 

) 

Plaintiffs, ) 

) 

v. 

) 

) 


) 

) 

and 

) 

) 


) 

Defendants. ) 

) 

************************************ 

CASE NO. 1:09-CV-2670 

CASE NO. 1:09-CV-2285 



THIRD STIPULATED ORDER AND 

FINAL JUDGMENT 

Exhibit 8

1. The Court previously granted the Parties’ Joint Motion for Approval of 


U.S.C. § 216(b). 

2. In its First Stipulated Order and Partial Final Judgment (“First Stipulated Order”), 

the Court approved the Settlement Agreement as fair and reasonable, granted final approval of 

the Settlement as to the Named Plaintiffs and the Existing Opt-In Plaintiffs, 1 and granted 

preliminary approval of the Settlement as to the Other Eligible Settlement Participants. 

3. The Settlement makes Individual Payments available to the Named Plaintiffs, the 

Existing Opt-In Plaintiffs, and Other Eligible Settlement Participants who sign and return the 

Consent and Release Form by the Early Deadline or the Final Deadline. The First Stipulated 

Order directed that the Notice and attached Consent and Release Form be mailed to the Existing 

Opt-In Plaintiffs and the Other Eligible Settlement Participants as provided in the Settlement 

Agreement. 

4. Following the Early Deadline, the Parties submitted, and the Court entered, the 

Second Stipulated Order and Partial Final Judgment. The Second Stipulated Order approved the 

issuance of Individual Payments to Existing Opt-In Plaintiffs who had signed and returned 

Consent and Release Forms by the Early Deadline. As to Other Eligible Settlement Participants 

who had done so, the Second Stipulated Order granted final approval of the Settlement and 

approved the issuance of Individual Payments. 

5. The Parties have now submitted this Third Stipulated Order and Final Judgment, 

and have attached to it (i) lists of all Existing Opt-In Plaintiffs and Other Eligible Settlement 

Participants who returned signed Consent and Release Forms after the Early Deadline but on or 


2

efore the Final Deadline, and (ii) copies of those individuals’ signed Consent and Release 

Forms (from which their addresses and social security numbers will be redacted). 

6. As to the Existing Opt-In Plaintiffs so listed, the Court approves the issuance of 

Individual Payments to them in accordance with, and subject to the terms and conditions of, the 


7. As to the Other Eligible Settlement Participants so listed, the Court grants final 

approval of the Settlement, and approves the issuance of Individual Payments to them in 

accordance with, and subject to the terms and conditions of, the Settlement Agreement. 

8. The Court dismisses with prejudice the claims of the Other Eligible Settlement 

Participants listed in this Third Stipulated Order, and enters final judgment dismissing these 

Lawsuits with prejudice. The Court directs the Clerk of Court to enter this Third Stipulated 

Order and Final Judgment immediately. 

9. The Court continues to retain jurisdiction over the Lawsuits for purposes of 

enforcement of the Settlement Agreement. 

Date: _________________________ 




3 

SO ORDERED: 

___________________________________ 




MITCHELL G. BLAIR (0010892) 


JOHN R. CERNELICH (0034697)






(216) 781-7956 [Telephone] 

(216) 781-8061 [Facsimile] 







(216) 696-5000 [Telephone] 

(216) 696-7005 [Facsimile] 


4 






(216) 622-8200 [Telephone] 

(216) 241-0816 [Facsimile] 






New York, NY 10004-1482 

(212) 837-6000 [Telephone] 

(212) 422-4726 [Facsimile] 








Telephone: (216) 363-4500 

Facsimile: (216) 363-4588 






Dated: March __, 2010 Dated: March __, 2010

IN THE UNITED STATES DISTRICT COURT FOR ... - Cleveland.com

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