The Plaintiff generally alleges that Amazon did not timely pay Plaintiff and Class Members any and/or all wages due at any time during the Class Period.

Amazon has expressly denied and continues to deny the claims in the Case and any liability. Amazon specifically denies that it failed to comply with Oregon wage and hour laws. Amazon asserted and continues to assert defenses to the claims, and expressly denied and continues to deny any wrongdoing or legal liability arising out of any of the facts or conduct alleged in the Case.  Neither the Settlement, nor any document referred to or contemplated in this notice, nor any action taken to carry out the proposed Settlement is, may be construed as, or may be used as an admission, concession or indication by or against Amazon of any fault, wrongdoing, or liability whatsoever. Amazon has concluded that the further defense would be protracted and expensive. Unless this Settlement is made, substantial amounts of time, energy and resources of Amazon will be devoted to the defense of the claims asserted. Amazon has, therefore, agreed to settle this Case in the manner and upon the Settlement terms in order to put to rest the claims that were or could have been asserted in the Case.

Amazon has agreed to pay up to $16,000,000.00 for all payments to Class Members, the Service Payment, Settlement Administration, employee and employer shares of applicable payroll tax payments, and Class Counsel’s Attorney Fees and Cost Award, allocated as follows and all subject to Court approval:

Settlement Awards:

Group A: All Class Members are included within Group A. Group A members shall receive a Settlement Award of $48.70 for the alleged unpaid wages in the Case. Group A members do not need to submit a Claim Form to receive this amount.

Group B: Those Class Members whose employment with Amazon ended during the Class Period are also members of Group B and shall be eligible to submit a Claim Form to receive an additional settlement award for $685.00 for the alleged penalty wages in the Case, which shall constitute part of their respective Settlement Awards. These individuals are also referred to as “Approved Claimants.”

Settlement Administration: $150,000.00 will be paid to Analytics Consulting LLC for administration of the Settlement.

Service Payment: $20,000.00 will be paid to the Plaintiff as a Service Payment for bringing this Case.

Class Counsel’s Attorney Fees and Cost Award: $5,333,333.33 for attorney fees and $4,423.00 for costs will be paid to Class Counsel.

Minimum Settlement Amount & Guaranteed Payments: Should the total of all payments to Class Members and Approved Claimants, Settlement Administration, Service Payment and Class Counsel’s Attorney Fees and Cost Award be less than $5,333,333.33, the difference between the amount paid and Minimum Settlement Amount shall be distributed on a pro rata basis to all Class Members in Group A.

All Class Members are entitled to a Settlement Award for Group A.

Only those that qualify for Group B are required to submit a Claim Form to receive the Group B Settlement Award. Amazon will not take any adverse action against you for participating in this Settlement.

You qualify for Group B if, based on Amazon’s records, your employment with Amazon in Oregon ended during the class period of April 16, 2019 through October 12, 2020. If you want to receive a Group B Settlement Award, you must submit a valid and timely Group B Claim Form. Those class members who qualify for Group A only do not need to submit a claim form.

If you do not want to be part of this Case and the Settlement, you can request to be excluded. If you request exclusion, you will not be bound by the Release of Claims and will not receive a Settlement Award.

Requests for exclusion must be in writing expressing your desire to be excluded from the Case and include: the case name and number, your full name and name while employed by Amazon, your current address, telephone number and last 4 digits of your social security number. To be valid and timely, your written request for exclusion must be mailed or emailed to on or before August 8, 2023:

Amazon Schumann Settlement Administrator
P.O. Box 2007
Chanhassen, MN 55317-2007
Email: info@AmazonSchumannSettlement.com

Requests for exclusion that do not include all required information, or that are not submitted by August 8, 2023, will be deemed null, void and ineffective. A timely request for exclusion shall supersede any other responses.

Objecting to the Settlement is telling the Court that you do not agree with all or some part of the Settlement. You can object only if you do not request exclusion from the class. If you request exclusion, you have no basis to object to the Settlement because the Settlement no longer affects you.

The objection must be a formal written statement objecting to the Settlement. The objection must include: your full name, your name while employed by Amazon (if different), your specific reason for objecting to the Settlement, whether you intend to appear and/or address the Court at the Final Approval Hearing, along with any and all documents that support your objection. Please note it is not sufficient to simply state that you object. You must give specific reasons why you believe the Settlement should not be approved.

For complete instructions for objections, please refer to the Notice.

A Final Approval Hearing will be held before the Honorable Jolie A. Russo on September 13, 2023, at 10:00 a.m. at the U.S. District Court for the District of Oregon. At the Settlement Hearing, the Court will determine whether the proposed Settlement should be approved as fair, adequate and reasonable, and whether the Case should be dismissed with prejudice. The hearing may be adjourned by the Court at the Court’s discretion without further notice.

You are not required to attend the Final Approval Hearing.

At the Final Approval Hearing, you will be represented by Class Counsel. You are welcome to attend the Final Approval Hearing at your own expense but you do not need to attend. You have the right to retain your own attorney separate from Class Counsel, but retention of that attorney is at your own cost. You do not need to get your own attorney unless you want to.

If the Settlement is not approved, the Case will proceed as if no settlement had been attempted. In that event, Amazon retains the right to contest whether the Case should be maintained as a class action and to contest the merits of the claims being asserted in this Case. If the Settlement is not approved, there can be no assurance that Class Members will recover more than is provided in the Settlement or anything at all.

The Court appointed the attorneys at Schuck Law, LLC as Class Counsel to represent the Class Members in this Settlement. You can contact the attorneys at Schuck Law at: 208 E 25th Street Vancouver, WA 98663; by phone (360) 566-9243, or by email at kmoore@wageclaim.org.