Frequently Asked Questions

1. Why did I get the notice?

You have received the Notice because Starbucks records show that you fit the definition of persons entitled to receive the Notice and to participate in the settlement of this class action lawsuit.

The Court ordered that you be sent the Notice because you have a right to know about the proposed settlement. the Notice explains the lawsuit, the proposed settlement, your legal rights, and what benefits are available to you.

The Court overseeing the lawsuit is the U.S. District Court for the Northern District of California, San Francisco Division. The lawsuit is entitled Adelman et al., v. Starbucks Corporation. The people who filed the lawsuit are called the “Plaintiffs.” Starbucks is referred to as the “Defendant.”

2. What is the lawsuit about?

Plaintiffs are former Starbucks partners who allege Starbucks store managers and assistant store managers in California used their personal cell phones for work without receiving proper reimbursement, wages for time worked, or premiums for interrupted breaks (the “Manager Claims”). They also allege Starbucks failed to pay sick pay and break premiums at the proper rate of pay to non-exempt California employees (the “Employee Claims”). They assert claims for failure to provide proper meal and rest break premiums, failure to provide accurate wage statements, failure to timely pay final wages, and unfair competition. Plaintiffs bring these claims on behalf of a putative class of California store partners and also seek civil penalties under the Private Attorneys General Act (“PAGA”) for the same alleged violations (the “PAGA Claims”).

Starbucks denies each and every allegation by the Plaintiffs and denies it did anything wrong. Starbucks maintains it properly paid its employees. The parties have entered into this settlement solely with the intention of avoiding further litigation.

3. What is a class action?

In a class action, one or more people called a “Plaintiff” file a lawsuit on behalf of himself or herself and other people who they contend have similar claims. Those people with similar claims are called “Class Members”. Class Members are part of the case and are bound by any judgment or settlement approved by the Court, unless they ask to be excluded from the case.

4. Why is there a settlement?

Starbucks maintains it properly paid employees for all hours worked and denies all allegations in the lawsuit. The Court did not decide in favor of Plaintiffs or Starbucks. Instead, both sides agreed to settle this case to avoid the cost, time, and uncertainty of further litigation. The Court has granted preliminary approval of the settlement. The settlement does not mean that Starbucks violated any law. Plaintiffs and their attorneys think the settlement is best for all Class Members.

5. How do I know if I will be included in the settlement?

You are a Class Member if you fit one or both of the following definitions:

1. Manager Class: All individuals who worked for Starbucks in California as a store manager or assistant store manager from June 27, 2015 to November 24, 2023.

2. Employee Class: All individuals who worked for Starbucks in California as a nonexempt employee from June 8, 2018 to November 24, 2023.

6. What does the settlement provide?

If the Court grants final approval of the settlement, the total settlement amount (“Global Settlement Fund”) will be $2,875,000. The Global Settlement Fund includes Class Counsel’s attorneys’ fees of $718,750, out-of-pocket litigation costs not to exceed $235,000, the cost of settlement administration (estimated not to exceed $119,000), payment of $150,000 to the California Labor and Workforce Development Agency to settle the PAGA Claims, payment of $60,000 to two cy pres beneficiaries, payments of $5,000 each to the named plaintiffs for releases of any other employment-related claims, and individual settlement payments to members of the Manager Class who participate in the settlement who do not exclude themselves from the settlement. The amount shared by Manager Class Members who do not exclude themselves from the settlement is called the “Net Settlement Fund.”

7. How will payments to the Manager Class be calculated?

The individual settlement payments to Manager Class Members who do not exclude themselves from the settlement will be calculated based on a formula that has been preliminarily approved by the Court as fair and reasonable. If the Court grants final approval of the settlement, each Plaintiff and each of the Manager Class Members who does not exclude themselves from the settlement (collectively, “Claimants”) will receive a pro rata share of the Net Settlement Fund based on the number of workweeks worked by the Claimant as store manager or assistant store manager from June 27, 2015 to November 24, 2023.

If you are a member of the Manager Class, your estimated payment is included in the Notice that was sent to you.

8. How do members of the Manager Class get their payment?

If you are a member of the Manager Class, to receive your payment, you are not required to do anything. Checks will be mailed to Manager Class Members at the addresses listed in Starbucks records. If your address has changed, you must contact Simpluris (the “Settlement Administrator”) and provide your current mailing address.

The Settlement Administrator’s complete contact information is:

Adelman et al. v. Starbucks Corporation
P.O. Box 26170
Santa Ana, CA 92799
www.StarbucksCaliforniaSettlement.com
(888) 406-0862
info@StarbucksCaliforniaSettlement.com

9. When will members of the Manager Class get their payment?

If the Court grants final approval of the settlement, members of the Manager Class will be sent checks after the Court holds a Fairness Hearing and grants final approval of the settlement.

It is your responsibility to keep a current address on file with the Settlement Administrator.

Please make sure to notify the Settlement Administrator of any change of address.

Checks will become null and void 120 days after their issuance.

10. Why are members of the Employee Class not receiving direct payment?

Members of the Employee Class are not receiving direct payments because the value of the claim is calculated to be approximately $60,000. However, there are approximately 168,000 members of the Employee Class. Therefore, the average payment would be approximately 35 cents. Therefore, the cost of preparing and mailing the check would exceed the value of the check itself. Under these circumstances, courts direct that a payment be made to charitable organizations. In this case, the Court has approved a total payment of $60,000 to two charitable organizations to be split evenly between: (1) Legal Aid Society – Employment Center in San Francisco, and (2) Bet Tzedek in Los Angeles. Both organizations provide, among other services, legal services to people who cannot otherwise afford them.

11. How can I exclude myself from the settlement?

To exclude yourself from the settlement, you must notify the Settlement Administrator in writing that you wish to be excluded from the settlement. To do so, you must mail your request for exclusion to:

Adelman et al. v. Starbucks Corporation
P.O. Box 26170
Santa Ana, CA 92799
www.StarbucksCaliforniaSettlement.com

Your request for exclusion must include your full name, address, telephone number, and the following case number: 3:20-cv-00178-JD. You must also sign your request for exclusion.

You must mail your request for exclusion postmarked by May 4, 2024.

12. What am I giving up if I do not exclude myself from the settlement?

If the Court grants final approval of the settlement, you will be bound by the release of claims, unless you have excluded yourself from the settlement in the manner described above. The Settlement Agreement includes the following release of claims:

1. Any and all claims (i) asserted in this Action on behalf of individuals who worked for Starbucks in California as a store manager or assistant store manager from June 27, 2015 to November 24, 2023, including in the Third Amended Complaint filed on June 8, 2022, or (ii) arising from, or derivative of, the claims or factual allegations asserted in this Action regarding Starbucks alleged failure to: reimburse managers’ business expenses, provide managers proper meal and rest breaks, pay managers wages for time worked, provide managers accurate wage statements, or timely pay final wages to managers; and

2. Any and all claims (i) asserted in this Action on behalf of individuals who worked for Starbucks in California as a nonexempt employee from June 8, 2018 to November 24, 2023, including in the Third Amended Complaint filed on June 8, 2022, or (ii) arising from, or derivative of, the claims or factual allegations asserted in this Action regarding Starbucks alleged failure to: pay meal and rest break premiums and sick pay at the regular rate of pay, provide employees accurate wage statements, or timely pay final wages.

When claims are “released,” that means you cannot sue Starbucks for any of the claims that are covered by the release.

13. How can I object to the settlement?

If you want to object to the settlement, you must send a letter saying that you object to the settlement in the case of Adelman, et al. v. Starbucks Corporation, N.D. Cal. Case No. 3:20-cv-00178-JD.

In your objection, you must include your full name, address, and telephone number and the specific reason(s) why you object to the settlement. Please be aware that the Court can only approve or deny the settlement but cannot change the terms of the settlement. Your letter must also indicate whether you intend to appear and object to the settlement at the Fairness Hearing. You must also sign your letter.

You must mail your objection to both of the addresses below so that it is postmarked no later than by May 4, 2024. Late objections will not be considered.

14. What is the difference between objecting and asking to be excluded?

Objecting is informing the Court that you do not like something about the settlement. You can object only if you do not exclude yourself from the settlement. Excluding yourself from the settlement is informing the Court that you do not want to be part of the settlement. If you exclude yourself, you cannot object because the case no longer affects you.

15. The Court's Fairness Hearing

The Court has scheduled a Fairness Hearing on July 25, 2024 at 10:00 a.m. at the United States District Court for the Northern District of California, San Francisco Division, Courtroom 11, 450 Golden Gate Avenue, San Francisco, California 94102

The hearing may be moved to a different date or time, so if you plan to attend, you should call or email the Settlement Administrator or Class Counsel for current information or check the website www.StarbucksCaliforniaSettlement.com. At this hearing, the Court will consider whether the settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court may listen to Class Members who have asked to speak about an objection. At or after the hearing, the Court will decide whether to grant final approval of the settlement.

Class Counsel will answer any questions that the Court may have. You do not have to come to the hearing, even if you submitted an objection. If you send an objection, you do not have to come to Court to talk about it. As long as you mailed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend.

16. Do I have a lawyer in this case?

The Court appointed Wynne Law Firm, Shavitz Law Group, P.A., Cohelan Khoury & Singer, and Davytan Law Firm to represent you and other Class Members as “Class Counsel.” You may call Class Counsel to discuss any questions you may have about this settlement using the contact information below. If you want to be represented by your own lawyer, and have that lawyer appear in court for you in this case, you may hire one at your own expense.

17. How will Class Counsel be paid?

Class Counsel will ask the Court to approve a fee not to exceed twenty-five percent (25%) of the Global Settlement Fund, or $718,750, for attorney fees in addition to reasonable actual expenses not to exceed $235,000 for out-of-pocket litigation expenses. The Court will decide whether to grant the request at the Fairness Hearing set for July 25, 2024 at 10:00 a.m. at the United States District Court for the Northern District of California, San Francisco Division, Courtroom 11, 450 Golden Gate Avenue, San Francisco, California 94102. Class Counsel have been prosecuting the Lawsuit on behalf of the Class on a contingency fee basis (that is, without being paid to-date) while advancing litigation costs and expenses. The fee and cost award will constitute full compensation for all legal fees and litigation expenses of Class Counsel in the Lawsuit, including any work they do in the future. Class Members are not personally responsible for any fees or litigation expenses.

18. How do I get more information?

This Notice summarizes the proposed settlement. More details about the settlement are in the Settlement Agreement. If you have other questions about the settlement, or if you would like a copy of the Settlement Agreement, you can contact Class Counsel using the contact information above. Alternatively, you may visit the settlement website available at: www.StarbucksCaliforniaSettlement.com or by accessing the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov, or by visiting the office of the Clerk of the Court for the United States District Court for the Northern District of California, 450 Golden Gate Avenue, San Francisco, California 94102, between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.

19. How do I change or update my address?

If you need to update your mailing address, please contact the Settlement Administrator at (888) 406-0862 or info@StarbucksCaliforniaSettlement.com.

PLEASE DO NOT CONTACT THE COURT WITH QUESTIONS ABOUT THE SETTLEMENT

Dated: Febuary 19, 2024