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

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