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November 14, 2014

NOTICE OF SETTLEMENT OF CLASS ACTION LAWSUIT


Raposo et al. v. Mardi Gras Entertainment, Inc. et al.,
Massachusetts Hampden County Superior Court Civil Action No. 10-00034
TO:

Dancers at the Mardi Gras Complex, Anthonys Gentlemens Club, Center Stage, Fifth Alarm, or Lace
between January 2007 and January 2010 and Bartenders at the Mardi Gras Complex between January 2007
and January 2010

I am writing to notify you that a proposed settlement has been reached in a class action lawsuit brought on behalf of
individuals who worked as Bartenders at the Mardi Gras Complex in Springfield, Massachusetts (Mardi Gras) and
individuals who worked as Dancers at Mardi Gras, Anthonys Gentlemens Club, Center Stage, Fifth Alarm, or Lace
(collectively, The Five Clubs). If you worked as a Bartender at Mardi Gras or as a Dancer at any of The Five Clubs
between January 11, 2007 and January 11, 2010 (Class Period), you may be eligible for a payment as described below.
The Plaintiffs in this lawsuit claimed that the Defendants misclassified dancers as independent contractors when they
were actually employees and that, as a result, certain compensation was not paid to the Dancers. The Plaintiffs also
claimed that certain compensation was not paid to Bartenders. The Defendants deny the allegations. There has been
no trial in the case and no finding by the Court of any wrongdoing.
The Parties have agreed to a proposed settlement on behalf of a class consisting of all individuals who, during the
Class Period, worked as Bartenders at Mardi Gras or as Dancers at any of The Five Clubs (Settlement Class).
The total amount of the proposed settlement is $1,800,000 (Settlement Amount). If the Court approves the settlement,
the portion of the Settlement Amount available for distribution to Class Members will be distributed in proportion
to the number of shifts that each Class Member worked during the Class Period, which will be determined based on
the best estimates that can be obtained from Mardi Gras and sworn verification of information provided by Class
Members through Claim Forms. Assuming prompt Court approval of the settlement, Class Members who submit
valid Claim Forms by January 20, 2015 will receive a payment in approximately February 2015. Class Members
who submit valid Claim Forms after this date but before May 15, 2015 will receive payment in approximately June
2015. If additional settlement funds remain in June 2015 beyond what is needed to pay late claimants, Class Members
who have submitted valid Claim Forms as of that time may receive an additional payment.
Class Counsel in this lawsuit is Shannon Liss-Riordan, Esq. of the law firm Lichten & Liss-Riordan, P.C., 729
Boylston Street, Suite 2000, Boston, MA 02116; (617) 994-5800; sliss@llrlaw.com; www.llrlaw.com. Class Counsel
has prosecuted this case on behalf of the Dancers and Bartenders and will ask the Court for an award of attorneys
fees consisting of one-third of the Settlement Amount plus expenses for prosecuting the lawsuit. Based on her
analysis of the case and broad experience litigating similar cases, Class Counsel believes that the settlement is fair,
reasonable, and adequate.
Under the proposed settlement, five individuals who claim to have worked for the defendants during the Class Period,
including Bartenders and a Dancer who served as lead Plaintiffs in this lawsuit and extensively assisted counsel, will
also receive additional payments in the amount of $25,000 each as incentive payments, which will be deducted from
the Settlement Amount and will compensate the lead Plaintiffs for their efforts in supporting the case on behalf of
other Class Members and working with Class Counsel to pursue it. In addition, two Plaintiffs who initiated this case,
and who claimed that they lost their jobs in retaliation for bringing these claims, will also receive compensation out
of the Settlement Amount in the amount of $75,000 each.
In order to claim a share of the Settlement Amount, you must complete and sign the enclosed Claim Form and
W-4 and W-9 tax forms and return them to the following address:
Raposo v. Mardi Gras Settlement Administrator
PO Box 5110
Portland, OR 97208-5110
E-mail: info@MardiGrasSettlement.com
Fax: 1 (844) 889-2197
You may also complete and submit an electronic Claim Form and W-4 and W-9 tax forms by visiting
www.MardiGrasSettlement.com. In either case, you must submit a valid Claim Form no later than January 20,
2015 in order to receive your first payment in February 2015. Class Counsel requests that interested Class Members
submit their Claim Forms by December 16, 2014, so that they are on file before the December 23, 2014 hearing.
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If you know of any other individuals who worked as Dancers at any of The Five Clubs or as Bartenders at
Mardi Gras during the Class Period who may not have received notice of the proposed settlement, you may
notify them of their ability to contact Raposo v. Mardi Gras Settlement Administrator for further information.
There will be a court hearing on December 23, 2014 at 9:30 a.m. at the Massachusetts Superior Court for Hampden
County, Civil A Session (Courtroom 8). The courthouse is located at 50 State Street, Springfield, MA 01102. At this
hearing, the Court will consider whether or not to approve this settlement. You are not required to attend this hearing
in order to participate in the settlement, but you are free to do so. Under Massachusetts law, you are free to object to
the settlement, but you may not opt out of the case. If the settlement is approved by the Court, you will be bound by
the settlement. As explained above, in order to receive a payment, you must complete and submit a valid Claim Form.
If you object to the proposed settlement, you must send a written objection to Raposo v. Mardi Gras Settlement
Administrator, PO Box 5110, Portland, OR 97208-5110 by December 16, 2014. You are also free to attend the
hearing on December 23, 2014, but in order to raise an objection, you must submit to the Raposo v. Mardi Gras
Settlement Administrator in writing by December 16, 2014 your name, address, and telephone number; information
sufficient to establish your membership in the Settlement Class; and an explanation of what your objection is to the
settlement.
Again, in order to claim a share of the Settlement Amount, you must promptly complete and submit a valid
Claim Form and W-4 and W-9 tax forms to Raposo v. Mardi Gras Settlement Administrator, PO Box 5110,
Portland, OR 97208-5110. Class Counsel requests that interested Class Members submit their Claim Forms
by December 16, 2014, so that they are on file before the December 23, 2014 hearing.
If you have any questions about this settlement, please feel free to contact Raposo v. Mardi Gras Settlement
Administrator, PO Box 5110, Portland, OR 97208-5110 or visit www.MardiGrasSettlement.com.

Sincerely,

Raposo v. Mardi Gras


Settlement Administrator

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